Vidyapurna Thirtha Swami, Minor, By ... vs Vidyanidhi Tirtha Swami (Died), A ... on 6 January, 1904
In the very learned judgments delivered in Vidyapurna, Tirtha Swami v. Vidyanidhi Tirtha Swami (1904) I.L.R. 27 Mad. 435, the distinction between those functionaries is explained. But a Dharmakartha is literally and no more than the manager of a charity, and his rights, apart it may be in certain circumstances from the question of personal support, are never in a higher legal category than that of a mere trustee.