HH Sant Baba Jeet Singh Ji Maharaj v Eastern Media Group & Anor

Reference: [2010] EWHC 1294 (QB)

Court: Queen's Bench Division

Judge: Eady J

Date of judgment: 17 May 2010

Summary: Defamation - Libel - Justiciabillity of claim - Issues of religious doctrine - Regulation or governance of religious groups

Instructing Solicitors: Ford & Warren for the Claimant; Sahota for the Second Defendant


C, the head of Nirmal Kutia Johal, a religious institution which follows the teachings of the Nirmal Sikh faith, brought libel proceedings over an article written by journalist Hardeep Singh which appeared in The Sikh Times in August 2007. The article claimed that C saw himself as a leader who should be worshipped personally and who required his followers to bow down to a picture of him, contrary to mainstream Sikhism. C alleged that it meant, among other things, that he was the leader of a cult and an impostor, had disturbed the peace in the Sikh community of High Wycombe, and promoted blasphemy and the sexual exploitation and abuse of women. Ds defended the claim, pleading justification, fair comment and qualified privilege.

On the first day of trial D2 made an application for a preliminary ruling on the issue of whether the claim should be stayed, either wholly or in part, on the basis of non-justiciability.


(1) Whether the issues between the parties on their pleaded cases fell within the well-established principle that the courts will not attempt to rule upon doctrinal issues or intervene in the regulation or governance of religious groups; and

(2) whether, so far as there may have been questions of pure fact which taken by themselves could readily be determined by the court in the usual way, the claim should go ahead despite the exclusion of primary doctrinal or other religious issues.


After close scrutiny of the pleaded meanings, the Defence and the Reply, Eady J found that there were key issues such as whether C was or was not fairly described as an “impostor” that could not be isolated and resolved without reference to Sikh doctrines and traditions.

The judge adopted the words of Gray J. in the case of Blake v Associated Newspapers, concluding that the present issues “… cannot be adapted so as to circumvent the insuperable obstacle placed in the way of a fair trial of this action by the fact that the court must abstain from determining questions which lie at the heart of the case”

Accordingly the claim was stayed.


Any case whose resolution turns upon questions of religious doctrine is likely to be stayed, following Blake.