As per case facts, 60 worshippers initiated proceedings under the Sikh Gurdwaras Act, 1925, to declare an institution in Jhandawala a Sikh Gurdwara, which was subsequently notified by the Government. ... However, the Mahant challenged this, asserting it was a Dera belonging to Nirmala Sadhus, a claim supported by a prior Supreme Court judgment which concluded that Nirmala Sadhus are not Sikhs and the institution was not a Sikh Gurdwara. Despite the Tribunal initially finding it a Sikh Gurdwara, the High Court reversed this, emphasizing the Supreme Court's earlier ruling and the burden of proof. The question arose whether the institution, previously deemed a Dera of Nirmala Sadhus in a Section 92 CPC suit, could now be declared a Sikh Gurdwara under the Sikh Gurdwaras Act, 1925, particularly concerning the identity of Nirmalas and the conclusive effect of prior judgments. Finally, the Supreme Court dismissed the appeal, affirming that the institution was not a Sikh Gurdwara. The Court upheld its previous findings that Nirmala Sadhus are not Sikhs and that the institution, maintained by them, did not belong to the Sikh religion. It clarified that the mere presence of Guru Granth Sahib does not make an institution a Sikh Gurdwara. The Court stressed that the onus to prove an institution is a Sikh Gurdwara rests on the claimant and the specific conditions under Section 16(2) of the Act were not satisfied. Furthermore, the prior judgment in the Section 92 CPC suit was considered a representative suit, binding on all interested parties and operating as res judicata, thereby precluding the re-agitation of the core issues.