The Maharaj Libel Case was an 1862 trial in the Bombay High Court in the Bombay Presidency, British India. The case was filed by Jadunathjee Brajratanjee Maharaj, against Nanabhai Rustomji Ranina and Karsandas Mulji. The case was filed because of an editorial article published by them accusing the Vallabhacharya and Pushtimarg Sect of certain alleged controversial practices that had been followed by the leaders. This case highlighted conflicts between traditional yet controversial social practices such as charan seva amidst emerging reformist ideas in colonial India, garnering significant public attention and praise for Mulji's efforts.[1][2][3][4]
The case arose when the plaintiff, Jadunathjee Brajratanjee Maharaj, a religious leader, filed a case of libel against a reformer and journalist Karsandas Mulji for writing an article in the newspaper, Satyaprakash, titled Hinduo No Asli Dharam Ane Atyar Na Pakhandi Mato (lit.'The True/Original Religion of the Hindus and the Present Hypocritical/phoney Sects'). In this article he questioned the values of a Hindu sect called the Pushtimarg or Vallabha Sampradaya. The article was claimed to be libelous by the plaintiff. In particular were accusations that Jadunathjee had sexual liaisons with women followers and that men were expected to show their devotion by offering their female family members for sex with the religious leaders.[5][6]
Jadunathjee was a religious leader of the Vaishnavite Pushtimarg sect of Hinduism. The sect was founded in the 16th century by Vallabha and worships Krishna as the supreme being. The leadership of the sect remained with Vallabha's direct male descendants who possess the titles of maharaja. Theologically Vallabha and his descendants are accorded partial divinity as mediating figures for Krishna's grace who are able to render Krishna's presence immediately to the devotee.[7][8]
Pushtimarg's followers in Gujarat, Kathiyawad, Kutch, and central India were rich merchants, bankers, and farmers, including the Bhatia, Lohana, and Baniya castes.[9] Many of these mercantile groups migrated to Bombay under British rule as the city was the political and financial capital of western India.[10] The merchant groups were headed by merchant-princes or seths who were heavily involved in the political and cultural milieu of Bombay. The seths, despite their general lack of education, ignorance of English language and British political traditions, were influential in Bombay society as leaders of business communities and maintainers of cultural honour.[11]
By the mid-nineteenth century the British had established political control over the Indian subcontinent and sought to create an administrative-legal framework to manage their colonial interests. British officials sought to compile Indian legal doctrines and apply them to British common law, effectively stripping native groups of civil and criminal self-governance in favour of a unified legal system. This desire to produce legal codes spawned the Orientalist school of Indology, whose grand narrative of Indian history was that of a decline from an ancient golden age into a degenerate, superstitious modern society. The British established schools and colleges that would educate new generations of Anglicized Indians who would be supportive of social reforms. These institutions created a new class of urban English speaking professionals who claimed to be superior leaders of society due to their intricate knowledge of the British administrative machinery. These English-speaking professionals joined various religious reform movements who concurred with the Orientalist view of modern Indian religion, and especially opposed the seths for their role in so-claimed excessive religious patronage.[11]
Goswami Jivanlal of Mumbai playing the sitar.
The Pushtimarg religious heads, the maharajas, began settling Bombay in the 19th century and by 1860 there were five maharajas in the city. The maharajas sought to exert control over their devotees and castes through seth intermediaries, and they were generally successful against anonymous reformers and caste solidarity. One such reformer was Karsandas Mulji, an English-educated reformer who was the editor of the Satyaprakash newspaper. Mulji came from an orthodox Pushtimarg merchant family who were highly respected in Bombay society; however Karsandas was disowned for his reformist views and had to drop out of Elphinstone College. Mulji became well known amongst Bombay reformists, and he launched attacks against the Pushtimarg and the Bombay maharajas for believed sexual depravity. Sexual allegations against the maharajas had first became public in 1855, and the senior-most maharaja in Bombay, Jivanlal, launched rebuttals against the reformers. Jivanlal attempted to silence criticism from Pushtimarg devotees by making his supporters sign a document that would censor their criticism of him under threat of excommunication.[12] Mulji decried Jivanlal's document as a "slavery bond", and in 1860 published a work claiming that Pushtimarg was a heretical sect which advocated sexual mistreatment of women. The Bombay maharajas then decided to bring in Jadunath Brijratan, a well-known maharaja from Surat, to defend their stances. Jadunath had several public and press debates with Mulji and other reformers.[13]
Eventually Jadunathjee Maharaj filed a libel case in the Bombay Supreme Court on 14 May 1861 against Karsandas Mulji, editor of Satyaprakash, a Gujarati weekly newspaper, and its publisher Nanabhai Rustomji Ranina, for defaming the plaintiff in an article published on 21 October 1860.[14]
Case and judgement
The defense's lawyers sought to have the case thrown out on the argument that Mulji's comments did not attack Jadunath personally but rather as a religious leader, and that a secular court did not have jurisdiction over religious matters. These attempts failed, and the British judges stated Jadunath had the right to defend his reputation in court, but that the case would give no value to Jadunath's status as a religious leader nor to Pushtimarg theology, but rather Jadunath would be treated as an ordinary citizen of the British empire whose actions would be viewed through the British laws of universal morality.[15]
Jadunath continued to use his traditional means of authority to defeat Mulji, and ordered seths to ensure the loyalty of devotees. In one instance Bhatia seths (including Gokuldas Lilahadhar) convened a meeting of two hundred people of their caste to further this aim. This meeting came to the attention of the British Supreme Court, which resulted in the Bhatia Conspiracy case in which the seths were convicted for mass witness tampering and forced to pay fines to the court.[16] That case made public the divisions growing in the devotional community over the status of the maharajas and their loyalty to them.[17]
Plaintiff's Case
Thirty-five witnesses were called by Jadunath's side to serve as character witnesses, all from mercantile castes and including several seths. The devotee witnesses did their best to defend Jadunath with the limited theological knowledge they possessed, but none knew Sanskrit or Braj Bhasha and were not fully versed in Pushtimarg history. One notable witness, Gopaldas Madhavdas, stated he did not know of any sexual immoralities conducted by Jadunath or any other maharaj, and stated they were highly honoured religious leaders of the merchant communities. Gopaldas viewed and venerated the maharajas as gurus rather than Krishna, but stated that others in the community did view the maharajas as incarnations of Krishna. Another witness, Jamunadas Sevaklal, gave a similar testimony stating he had no knowledge of immoralities or sexual orgies of the maharajas, and stated the maharajas in his view were gurus who were the representations of Krishna although others worshipped them as gods. When Gopaldas and Jamunadas were directly questioned on whether the maharajas were gods or humans, they were confused and could not provide definite answers.[18]
Jadunath himself took the stand, and claimed knowledge of Sanskrit, Braj Bhasha, and Gujarati, but then later stated he had never actually read any Braj Bhasha Pushtimarg text. When asked about certain texts that supported the veneration of maharajas, Jadunath stated he was personally unfamiliar with those texts and at one point in the trial claimed the Shrinathji Temple was in Kankroli rather than Nathdwara. Jadunath stated that the maharajas were simply mortal spiritual guides and that only their ancestor Vallabha was an incarnation of Krishna. He stated the veneration the maharajas received was in accordance with Hindu scriptures and that only the maharajas could directly worship the Krishna images, so devotees would worship the maharajas. He denied all sexual allegations relating to him and any other maharajas, stating the adulterous love of Krishna and the gopis in Vrindavan was merely a metaphor for the relationship between devotees and Krishna, not an endorsement of infidelity.[19]
Defense's Case
Engraving of John Wilson
Karsandas Mulji himself took the stand, and stated the maharajas were oppressive leaders who encouraged sexual debauchery. He stated that Jadunath should rather be sued for libel, given his public attacks against Mulji. Mulji restated his earlier claims that the Pushtimarg was not the "true" Hinduism of the Vedic age, but rather a heretic sect that encouraged devotees to hand over their wives and daughters for the maharajas' pleasure.[20]
Image of Bhau Daji
A missionary, Reverend John Wilson, also took the stand. Wilson claimed knowledge of Sanskrit and Old Hindi as well as the Vedas, Puranas, and Shastras, and was thus sent by the defense as an authority on Hinduism. Wilson however was not intimately familiar with the Pushtimarga, and referred to Professor H. H. Wilson's works on the sect. He criticized the maharajas for the practice of lavish seva to Krishna, which he stated was in opposition to the asceticism of "true" Hinduism. He stated the maharajas were uneducated spiritual leaders who were worshipped as incarnations of Krishna solely due to their genealogical descent from Vallabha, and that their religious scriptures sanctioned the offering of devotees' wives and daughters to them.[21]
Two expert witnesses were also brought to the stand, Bhau Daji and Dhiraj Dalpatram, who were physicians to Jadunath. They said that they had treated Jadunath and other maharajas for syphilis, which they stated was due to sexual relations with female devotees. Dalpatram even stated that Jadunath had himself admitted to him that he had caught the disease from a female devotee.[22]
Other witnesses, such as Mathuradas Lowjee, supported the physician's testimonies. Lowjee was a member of the Pushtimarg, but ever since sexual allegations against the maharajas became public in 1855, he kept his distance from the maharajas and refused to venerate them all the while maintaining his theological commitment to the sect. He stated that Pushtimarg devotees, including members of his own Bhatia caste, viewed the maharajas as literal incarnations of Krishna. He stated senior members of the caste had "Ras Mandalis", which re-enacted the dances between Krishna and the gopis. He stated he once stumbled upon a maharaja having sexual intercourse with a female devotee. When Lowjee asked Jivanlal to stop the maharajas illicit behaviour, Jivanlal told him that he could not due to the powerful addiction of male sexual desire, as well as the fact that women's donations were a major source of financial income for the sect.[23]
Lakhmidas Khimji confirmed Lowjee's testimony, stating he once observed Jadunath grope the breasts of a fourteen year old girl and later stumbled upon Jadunath having sexual intercourse with her. Khimji stated on a few occasions he observed a widow companion of Jadunath procure married women for his sexual pleasure. Kalabhai Lalubhai also claimed Jadunath had sexual relations with women and girls as young as fourteen.[24]
Judgement
Justice Arnould
Justice Joseph Arnould ruled in favour of Mulji. Arnould was particularly influenced by Reverend Wilson's and Bhau Daji's testimonies. Arnould stated that Mulji's comments in Satyaprakash were not false and not specifically attacking Jadunath. Arnould agreed that the Pushtimarg was a degraded sect of Hinduism that promoted debauchery and loose morals. He stated Mulji did nothing wrong in exposing the "evil and barbarous" practices of the maharajas.[25]
Chief Justice Sausse
Chief Justice Matthew Richard Sausse was the senior of the two judges in the case, and overruled Arnould's judgement to find Mulji guilty of libel. Sausse was also greatly impressed by the defense's witnesses, which in his view affirmed the defendant's claim that the Pushtimarg was a heterodox sect and that Jadunath engaged in salacious behaviour. However, Sausse ruled that Mulji took a private dispute within the Pushtimarg and published his grievances in a public newspaper which was a form of malice. Sausse stated Mulji attacked Jadunath publicly without provocation, and that even if the sexual allegations against Jadunath were true, they were a private matter and newspapers could not attack people on private matters without public interest. Nevertheless, Sausse suspected the reliability of Jadunath and his witnesses' testimonies and only awarded him five rupees on the libel charge. Sausse sided with the defendants on the pleas that the Pushtimarg was a heterodox sect and agreed that the defendant's publications were true, and awarded Mulji eleven thousand five hundred rupees.[26][14][27]
Reaction
The libel case stirred unprecedented interest in the public. Karsandas Mulji's efforts and the court decision received praise from the liberals and the press.[14][28] For his part, Mulji was cited by the local English press as 'Indian Luther', after the Christian reformer Martin Luther.[29]
During and after the case, Pushtimarg devotees struggled to come to terms with the sexual allegations against the maharajas. Generally, devotees continued to have social contact with the maharajas as their religious leaders. In the next two decades however, some merchant devotees in Bombay built new temples and theological journals independent of the maharajas.[30]
In 1875, Dayananda Saraswati came to Bombay and attacked the Pushtimarg on similar lines as Mulji, calling it a heterodox sect with false religious leaders who contradicted "true" Hinduism.[31]
In popular culture
Maitri Goswami, Dhawal Patel et al. have written a book titled Doctrines of Pushtibhaktimarga: Allegations, Conspiracies and Facts (In context of Maharaj Libel Case)[6] based on the case.
Saurabh Shah, Gujarati author and journalist, wrote a novel titled Maharaj based on the case[32] which was awarded the Nandshankar award by the Narmad Sahitya Sabha.[33]
Goswami is an Indian surname and honorific title used by Brahmins and Hindu ascetics. It is also pronounced as, Gosains, Gosine, Gossain, Gosain, Gossai and Gosavi.
Bochasanwasi Akshar Purushottam Swaminarayan Sanstha is a Hindu denomination within the Swaminarayan Sampradaya. It was formed in 1905 by Shastri Yagnapurushdas following his conviction that Swaminarayan remained present on earth through a lineage of gurus starting with Gunatitanand Swami. As of August 2016, Mahant Swami Maharaj is the 6th guru and president of BAPS.
Karsandas Mulji was an Indian journalist, social reformer and administrator.
Vallabha, or Vallabhacharya, was an Indian saint and philosopher. He founded the Kr̥ṣṇa-centered Puṣṭimārga sect of Vaishnavism in the Braj (Vraja) region of India, and propounded the philosophy of Śuddhādvaita.
The Puṣṭimārga, also known as Pushtimarg or Vallabha Sampradāya, is a sect within the Vaishnavism tradition of Hinduism. It was established in the early 16th century by Vallabha (1479–1531) and further developed by his descendants, particularly Viṭṭhalanātha. Followers of the Puṣṭimārga worship Kr̥ṣṇa and engage in devotional practices centered around the youthful Kr̥ṣṇa as depicted in the Bhāgavata Purāṇa, and the pastimes at Govardhan Hill.
Vitthala-natha or Vitthalanath, popularly known as Gusainji, was an Indian philosopher. He was the younger son of Vallabhācārya, who founded the Puṣṭimārga Sampradāya of Hinduism.
Gokul is a town in the Mathura district of the Indian state of Uttar Pradesh. It is located 15 kilometres (9.3 mi) south-east of Mathura.
Gunatitanand Swami, born Mulji Jani, was a prominent paramhansa of the Swaminarayan Sampradaya who was ordained by Swaminarayan and is accepted as the first spiritual successor of Swaminarayan by the Bochasanwasi Akshar Purushottam Swaminarayan Sanstha (BAPS). Born into a religious family in the small farming community of Bhadra in Gujarat, India, he first received religious education under his father's guru, Ramanand Swami, before encountering Swaminarayan and becoming a swami under him at the age of 25. He was revered for his spiritual discourses and divine service.
Shuddadvaita is the "purely non-dual" philosophy propounded by the Hindu philosopher Vallabha, the founder of Puṣṭimārga, a Vaishnava tradition focused on the worship of the deity Krishna. Vallabhacharya's pure form (nondualist) philosophy is different from Advaita.
Narmadashankar Lalshankar Dave, popularly known as Narmad, was an Indian Gujarati-language poet, playwright, essayist, orator, lexicographer and reformer under the British Raj. He is considered to be the founder of modern Gujarati literature. After studying in Bombay, he stopped serving as a teacher to live by writing. During his prolific career, he introduced many literary forms in Gujarati. He faced economic struggles but proved himself as a dedicated reformer, speaking loudly against religious and social orthodoxy. His essays, poems, plays and prose were published in several collections. His Mari Hakikat, the first autobiography in Gujarati, was published posthumously. His poem Jai Jai Garavi Gujarat is now the state anthem of Gujarat state of India.
Bania is a mercantile caste mainly from the Indian states of Gujarat and Rajasthan, with strong diasporic communities in Uttar Pradesh, Madhya Pradesh, West Bengal, Maharashtra and other northern states. Traditionally, the main occupations of the community are merchants, bankers, money-lenders, and owners of commercial enterprises.
The Swaminarayan Sampradaya, also known as Swaminarayan Hinduism and Swaminarayan movement, is a Hindu Vaishnava sampradaya rooted in Ramanuja's Vishishtadvaita, characterized by the worship of its charismatic founder Sahajanand Swami, better known as Swaminarayan (1781–1830), as an avatar of Krishna or as the highest manifestation of Purushottam, the supreme God. According to the tradition's lore, both the religious group and Sahajanand Swami became known as Swaminarayan after the Swaminarayan mantra, which is a compound of two Sanskrit words, swami and Narayan.
Dayaram (1777–1853) was a Gujarati poet of medieval Gujarati literature and was the last poet of the pre-British Gujarati school. He is known in Gujarati literature for his literary form called garbi, a lyric song. He was a follower of Pushtimarg of Hindu Vaishnavism. Dayaram, along with Narsinh Mehta and Meera, is considered a major contributor during the Bhakti movement in Gujarati literature.
Gosains (गोसाईं), who are also known as Gossain, Gosine, Gossai, Gosavi, and as Goswamis, are Brahmins, Hindu ascetics and religious functionaries of India. Found chiefly in northern, central and western India, they have different histories by place and time. Even the name Goswami has been variously interpreted as 'master of cows', 'master of mind or intellect', 'master of senses or emotions' and 'master of passion'.
Shyam Manohar Goswami also known as Shyamu Bava, is the 16th descendant of Shri Vallabha Acharya, sanskritists, philosopher, spiritual leader, active reformer & guru of the Krishna-centered Pushtimarg sect of Vaishnavism.
Françoise Mallison is a French Indologist specialising in the history and religious traditions of Gujarat. She was the Head of Studies at the École pratique des hautes études, Sorbonne.
Satyaprakash was a Gujarati language weekly founded by social reformer and journalist Karsandas Mulji with an intention of social reform. Launched in 1855, it ran until 1861 and later was merged with Rast Goftar, another newspaper published in Bombay.
Hindus form 79.83% of the state's total population as per 2011 census. Hindus form the majority in all the districts of the state.The religion plays an important role in the lives of the Maharashtrian people in their day-to-day life. Vitthoba, along with other incarnations of Vishnu such as Rama and Krishna, Hanuman, Dattatreya, and Shaiva deities such as Shiva, Parvati, and Ganesha, are popular with Hindus of Maharashtra. The Varkari tradition holds a strong grip on the local Hindus of Maharashtra. The public Ganesha festival started by Bal Gangadhar Tilak in the late 19th century is very popular. Marathi Hindus also revere Bhakti saints associated with varkari sects such as Dnyaneshwar, Savata Mali, Tukaram, Namdev, Janabai, and Chokhamela. Many religious figures from 19th and 20th century are revered. They include Swami Samarth, Gajanan Maharaj, Sai baba of Shirdi, Tukdoji Maharaj, Gondavalekar Maharaj, and Gadge Maharaj.
Dwarkadhish Ji is a Hindu Temple, situated on the southern bank of the Rajsamand lake in Kankroli. The temple commands a very fine view of the lake. This temple is temple is dedicated to Dwarkadhish Ji, one of the seven swaroops of Pushtimarg of Vallabhacharya.
Maharaj is a 2024 Indian Hindi-language historical drama film directed by Siddharth P. Malhotra and produced by YRF Entertainment. It stars Junaid Khan in his film debut with Jaideep Ahlawat, Shalini Pandey and Sharvari. The film is based on the Maharaj Libel Case of 1862 and Saurabh Shah's novel about the case.
↑ Maharaj Libel Case Including Bhattia Conspiracy Case, No. 12047 o f 1861, Supreme Court Plea Side: Jadunathjee Birzrattanjee Maharaj Vs Karsondass Mooljee and Nanabhai Rustamji. Bombay: D. Lukhmidass & Co. 1911. pp.399, 419.
Saha, Shandip (2004). Creating a Community of Grace: A History of the Puṣṭi Mārga in Northern and Western India (1493-1905) (Thesis). University of Ottawa.
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