In Singh v. Second Judicial District Court of the State of Nevada, (NV Sup. Ct., April 2, 2026), a 3-judge panel of the Nevada Supreme Court held that the neutral principles exception to the ecclesiastical abstention doctrine applies beyond disputes over ownership of church property. At issue was whether the Management Committee of the Northern Nevada Sikh Society, without approval of the general membership, had authority form a subcommittee to transfer the Sikh Temple building into a trust. The court said in part:
[A]bsent [U.S.] Supreme Court authority holding otherwise, we now clarify that the neutral-principles exception to the ecclesiastical abstention doctrine may apply beyond real property disputes among church members. Rather, the relevant inquiry for courts to resolve is whether the court is able to apply neutral principles of law to resolve the issues at hand without consideration of ecclesiastical or doctrinal matters.... In other words, when neutral principles of law can resolve the underlying dispute, then the ecclesiastical abstention doctrine does not apply....
... [T]he issues raised in the complaint do not require the district court to resolve ecclesiastical questions or consider Sikh doctrine, practice or texts.... [T]hese claims ...arise from NNSS's Management's purported failure to follow NNSS's bylaws in forming two committees, attempting to place the Temple in trust, in not maintaining adequate membership records, and in restricting members from inspecting NNSS's books and records.
