Can a religious place be considered a “juristic personality” as per law?

Courts in India have held that Hindu idols are legal entities. An idol is the physical manifestation of a deity, and that’s why courts accept the premise of them being a legal person having specific rights and obligations. However, a birthplace or any holy land is not considered a legal entity. The apex court has held that a piece of land, in the absence of any physical manifestation of the religious deity it is supposedly tied to, cannot be considered a juristic person. The land can, however, be held by a trust for religious or other purposes and the rights and responsibilities accrue to that trust.