The duties of a manager of a graveyard are secular, and, therefore, a woman can be appointed as mutawalli. The general rule is that in all those cases where the spiritual or religious functions can be discharged by a deputy, there cannot be any objection to the appointment of a woman as mutawalli Thus, a woman cannot be sajjajdanashin (spiritual head), khatib (one who reads sermons), mujavai of a dargah, an imam of a mosque (one who leads congregation), or a mulla.

In Syed Mahomed Ghose v. Sayabiran, the Madras High Court observed that where the court is required to appoint a mutawalli, whether the duties are secular or religious, it must prefer to appoint a male mutawalli, since Muslim women observe pardah. The Supreme Court in Md. Zainulasideen v. Moideen has classified the position further by holding that a woman can be the manager or mutawalli.

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It has been held that a woman can hold offices of both mutawalli and sajjadanashin. She can perform secular functions herself and spiritual functions can be performed by her through a deputy or a proxy.