# Mann v. Sikh Nat'l Ctr., Inc. Supreme Court of Texas, No. 24-0828 **Mann v. Sikh Nat'l Ctr., Inc., No. 24-0828, is before the Supreme Court of Texas. Key issue: The Court denied a petition for review in a fight over control of the Sikh National Center's board and bank accounts that raised whether a trial court that lacks subject-matter jurisdiction under the ecclesiastical-abstention doctrine may still award attorney's fees under the Uniform Declaratory Judgments Act, and Justice Young concurred in the denial.** Practice areas: attorney fees, civil procedure, business organizations ## Key issues - The Court denied a petition for review in a fight over control of the Sikh National Center's board and bank accounts that raised whether a trial court that lacks subject-matter jurisdiction under the ecclesiastical-abstention doctrine may still award attorney's fees under the Uniform Declaratory Judgments Act, and Justice Young concurred in the denial. - The concurrence tentatively viewed a court wholly lacking jurisdiction over a UDJA claim as unable to award fees on that claim, though fees may be available for litigating the jurisdictional question itself, but said the case was a poor vehicle because the trial court's rulings were unclear and the parties changed their jurisdictional positions. ## Factual History Sikh National Center, Inc. (SNC), a nonprofit that operates a place of worship, sued its former directors and members, Manohar Singh Mann, Narinder Singh Nagra and Bhupinder Singh, and Wells Fargo, alleging they held a sham election, asserted rights to and interfered with SNC's bank accounts and opened an unauthorized account; SNC sought declaratory and injunctive relief and UDJA fees. The petitioners filed a plea to the jurisdiction under the ecclesiastical-abstention doctrine while also counterclaiming for a declaration that their actions were authorized, and filed a separate suit for access to financial records under Business Organizations Code § 22.351 (Young, J., concurring, PDF pp. 2-3). ## Procedural History The trial court denied a temporary injunction, stating it lacked jurisdiction under ecclesiastical abstention, but did not dismiss the case; it consolidated the records suit, granted SNC summary judgment ordering the petitioners to abide by SNC's February 2021 board vote, ordered SNC to produce documents and, after a bench trial on fees, awarded SNC fees. The Fourteenth Court of Appeals affirmed, holding the UDJA permits a fee award even without jurisdiction over the merits and that fees could rest on the petitioners' own UDJA claims (2024 WL 3616685). The Court denied the petition for review on July 25, 2025, and denied rehearing on October 10, 2025 (Young, J., concurring, PDF pp. 3-4; Docket). ## Issues Presented Whether the trial court lacked subject-matter jurisdiction over any part of the dispute, including the fee award, because of ecclesiastical abstention; whether the court of appeals' statement that fees could be awarded even without jurisdiction over SNC's claim was wrong; and whether the fee award was based on the petitioners' own claim (Petition for Review, PDF p. 11). ## Legal Arguments **Mann, Nagra, and Singh (Petitioners):** the court of appeals had to decide jurisdiction first, the UDJA is only a procedural device that does not confer jurisdiction, and they won all relief on their records suit yet were charged SNC's fees. **SNC (Respondent):** their ecclesiastical arguments are red herrings given their own non-ecclesiastical records claim, they failed to preserve their fee arguments, and courts may award UDJA fees regardless of jurisdiction over the merits (Petition for Review, PDF pp. 11, 24-25; Response to Petition, PDF p. 8). ## Stated Reasons the Court Should Take the Case Not applicable—the petition was denied. ## Practice Area Tags attorney-fees, civil-procedure, business-organizations ## Procedural Posture/Vehicle Petition for review from the Fourteenth Court of Appeals in an appeal from a fee award after summary judgment; denied July 25, 2025, and rehearing denied October 10, 2025 (Docket). ## Amicus Involvement None noted ## Court's Reasoning The concurrence noted that the UDJA lets a court award reasonable, equitable, and just fees to either party without ruling on the merits (Yowell v. Granite Operating), while Texas Right to Life v. Van Stean held that TCPA fees are unavailable when no court had jurisdiction, and that courts always have jurisdiction to decide their own jurisdiction so fees for that litigation may be permissible. The case was a poor vehicle because the trial court did not dismiss despite saying it lacked jurisdiction, the court of appeals rested partly on the petitioners' own UDJA claims, and the petitioners first argued in a motion for rehearing that the court lacked jurisdiction over all claims; it also observed that church-autonomy jurisdictional limits are granular and do not necessarily bar the whole dispute (Young, J., concurring, PDF pp. 1-9). ## Disposition Petition for review denied (Docket). ## Vote Breakdown Justice Young concurred in the denial of the petition for review (Young, J., concurring, PDF pp. 1-9). --- Source: The SCOTX Report, https://scotxreport.com/cases/24-0828. AI-generated summary of the Court's opinion, orders and the parties' briefs, with pin cites to the page of each document; verify against the Court's own documents at search.txcourts.gov.