Ram Lalla's 'next friend' or 'sakha'

 In its unanimous verdict that brought down the curtains on the decades-old Ram Janmabhoomi-Babri Masjid title dispute case, a five-judge Supreme Court bench declared Ram Lalla as a juristic person. A juristic person is a non-human legal entity recognised by the law and entitled to rights and duties in the same way as a human being.

“In the present case, the first plaintiff has been the object of worship for several hundred years and the underlying purpose of continued worship is apparent even absent any express dedication or trust….. At the heart of the present dispute are questions pertaining to the rightful manager of the deity and the access of the devotees of Lord Ram to the idols. To ensure the legal protection of the underlying purpose and practically adjudicate upon the dispute, the legal personality of the first plaintiff is recognised,” the court said.

Analysing its own judgements of the past the top court said legal personality even may be conferred on an abstract idea. In addition, legal personality is conferred on Hindu idols to provide courts with a conceptual framework to adjudicate disputes involving claims over disputed property endowed to or appurtenant to Hindu idols.

Order 32 of CPC recognises a 'sitting deity' as an individual. As in the eyes of the law, the sitting deity is a perpetual minor the court appointed him the 'sakha' the day his petition was admitted. Ram sakha's counsel, Madan Mohan Pandey, said, "Since the deity is a perpetual minor, he had to be represented by his 'friend'. Any person who has no interest prejudicial to the interest of the deity and is a Hindu worshipper of the Lord can apply for appointment in this capacity."
 
Ram Lalla was first represented by a next friend in 1989, when Deoki Nandan Agarwal, a judge of the Allahabad high court, filed a petition in the Faizabad district court in connection with the Ayodhya dispute. A resident of Allahabad's Katra Mohalla, he spent his childhood in Faizabad where his father was an inspector of schools and his mother, a devotee of Lord Ram. The Agarwal family was Vaishnav. For several years, Agarwal was the president of Aurobindo Society.

After retiring in 1983, Agarwal went to Faizabad and collected data, including revenue records, to prove that the land belonged to Ram Lalla. He filed a writ petition at Allahabad High Court's Lucknow bench on July 1, 1989 seeking his appointment as Ram Lalla's 'sakha' (friend). As 'Ram sakha', Agarwal filed civil suit no 5 on behalf of the deity at Ram Janmabhoomi and Asthan Janmabhoomi, where Ram Lalla was represented as plaintiff no. 1. The merits of suit number 5, many believe, is what tipped the balance in favour of Ram Lalla. Senior BJP leader Lalji Tandon said, "I met Agarwal many times during my tenure as a minister. He was committed to the cause of Ram Lalla. His deep knowledge of the law made the case in the title suit stronger."

He worked late into the night for years on the filing and told his daughter, Minu, that he was typing up “the most important case in India,” she said in an interview.
Justice Agarwal was frustrated by how slowly the litigation over the site was proceeding. He believed the evidence was clear that the site belonged to Ram, his daughter said.

 Deoki Nandan Agarwal died on April 8, 2002 after which an application was made to the court to allow T.P Verma, a retired history professor at BHU, to be appointed as next friend of Ram Lalla. In 2008, Verma applied for retirement from the status of "next friend" or "sakha" , citing old age and ill health.  In February 2008,Vishwa Hindu Parishad leader Triloki Nath Pandey, became next friend — a next of friend is a person who acts on behalf of another individual who does not have the legal capacity to act on his or her own behalf. A resident of Ballia's Daya Chhapra village, Pandey's association with Ram Lalla began in 1974 when he became an RSS 'pracharak'. In 1982, he joined the party's Sanskriti Raksha Yojana. He moved to Karsevakpuram in 1992 .