Pavisthinahamy v. Rev. Akurala Seelawansa Thero – sllr 1985 volume 2 page 197

In the matter between Pavisthinahamy (as the Viharadhipathi of the Abhinavaramaya Temple) and Rev. Akurala Seelawansa Thero, the court examined whether a Buddhist temple may be recognized as a juristic person capable of receiving and holding property under a deed of gift which included a fideicommissum clause. The court determined that a Buddhist temple, not being a natural or incorporated legal person, lacks legal capacity to receive property, thereby finding that no valid title passed to the temple upon the death of the original donee. The judgment underscored that only natural or legally created persons may be the subject of property rights. Furthermore, the introduction of new mixed fact-law issues for the first time on appeal was found to be inadmissible. The decision rested upon esta