Gurdwara Dashmesh Darbar, Inc. (“GDD”) is the largest gurdwara, or Sikh temple, in New Jersey. In May 2025, four of its life members sued to stop an election in which 361 new members, whose admissions had never been approved by GDD’s Governing Body Council, were set to vote. On October 5, 2026, the Superior Court of New Jersey, Chancery Division, Middlesex County, granted partial summary judgment to our clients in Johal v. Gurdwara Dashmesh Darbar, Inc., Docket No. MID-C-78-25, holding that the 361 were not validly admitted as life members and may not vote on that basis. The decision follows earlier injunctive relief we obtained halting the disputed election, and a summary judgment record we built through discovery, including eight depositions.
The ruling turned on GDD’s Bylaws, which require the full Governing Body Council to approve each membership application. Here, a three-member Election Committee approved all 361 applications itself. Applying the New Jersey Nonprofit Corporation Act, which limits committees to the authority actually given to them, the Court held that the Committee could not stand in for the Council.
The Court denied the defendants’ motion for summary judgment, vacated the June 10, 2025 election, and ordered a new election for all 31 Council seats. That election will be supervised by a neutral, Court-appointed Special Adjudicator and based on the membership roll as it stood before the November 2024 membership drive. Other claims in the case, including allegations of fraud and breach of fiduciary duty, remain for later proceedings.
The decision confirms that courts will enforce a religious nonprofit’s bylaws on secular governance questions, using neutral principles of law and without touching matters of faith.
For further information or to discuss, please contact Saad Admani, Esq. at sadmani@admanilaw.com or 201-241-2276.
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