Priest Hide Identity While Running Zen Centre: Madras High Court Rejects FCRA Registration

The Madurai Bench of the Madras High Court has upheld the Central Government’s decision to reject the application for registration under the Foreign Contribution Regulation Act (FCRA) filed by the Kanzeon Public Charitable Trust, based in Kodaikanal. The trust operates a Zen meditation centre and a Montessori school.

The court specifically noted that the key person and “moving spirit” behind the trust, Rev. Fr. Ama Sami S.J., is an ordained Christian priest. However, the trust had not properly disclosed its religious character in its application. While it claimed to follow Zen Buddhist philosophy, a statue of Buddha as well as a Christian cross were prominently displayed at the centre. The court viewed this as concealing its identity and providing inadequate information.

A division bench comprising Justice G.R. Swaminathan and Justice M.D. Sumathy observed, “One cannot keep a card up one’s sleeve. This is not a game of hide and seek.” The court further observed that Christianity is a messianic, or saviour-centred, religion and that its theological mission is to bring everyone into the faith of Jesus Christ. The court also observed that “Hinduism is inclusive, whereas the Abrahamic religions are inherently exclusive.”

The court clarified that religious organizations whose activities do not affect the country’s secular framework and social harmony may be granted FCRA registration. However, organizations involved in converting people from one religion to another should not be granted such registration. The court stated that this principle applies to all religions. It also clarified that it was not directly accusing this particular trust of carrying out religious conversions, but that the registration could be denied because of the concealment of its identity in the application.

Important Madras High Court Decision

FCRA Registration Denied to Kanzeon Trust

The trust was established in 2021 and is registered under the Income Tax Act. It had applied for FCRA registration, but the Ministry of Home Affairs rejected the application. The High Court dismissed the appeal on October 6, 2026.

The decision highlights the need for greater scrutiny and transparency among organisations receiving foreign funds, particularly religious organisations. The court also made it clear that there is no fundamental right to receive foreign contributions; receiving such contributions is a privilege.

The decision demonstrates that organisations seeking foreign funding must maintain complete transparency regarding their religious identity and activities. The court has taken a strict view of cases involving the concealment of a priest’s identity or organisations operating under a mixed religious identity.