On the Sabarimala temple entry case
As a Supreme Court Bench examines the broader implications of its 2018 Sabarimala ruling, the case prompts a look into the evolution of the essential religious practice doctrine, role of the State and the judiciary in religious reform, and the arguments over whether Ayyappa followers qualify as a religious denomination
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Context
A nine-judge Constitution Bench of the Supreme Court is currently reviewing the broader legal questions arising from the landmark 2018 Indian Young Lawyers’ Association vs. State of Kerala judgment. The 2018 verdict struck down age-based restrictions on women entering the Sabarimala temple, citing violations of equality and dignity. This ongoing review is crucial as it seeks to resolve the wider conflict between individual fundamental rights and collective religious freedoms across various faiths in India.
UPSC Perspectives
Polity
The core constitutional conflict in this case revolves around the friction between the right to equality and non-discrimination ( and ) versus the freedom to manage religious affairs (). In 2018, the court held that devotees of Lord Ayyappa do not constitute a distinct religious denomination under , thereby denying them absolute autonomy to exclude women based on custom. Furthermore, the judiciary heavily relied on the doctrine of —first established in the 1954 —to determine if excluding women is a fundamental tenet of the Hindu religion. Because the practice was deemed non-essential, the fundamental rights to equality and access to public places of worship prevailed. UPSC aspirants must understand this delicate balancing act, as it defines the limits of state intervention in religious matters.
Social
The exclusion of women aged 10-50 from the temple was historically rooted in patriarchal notions of ritual "purity" and the biological phenomenon of menstruation. The court recognized that barring women based on physiological functions directly violates their right to live with dignity, which is implicitly protected under . This ruling is a prime example of transformative constitutionalism, wherein the Constitution acts as an instrument to dismantle deeply entrenched, orthodox social structures that discriminate against marginalized groups, including women. The apex court asserted that constitutional morality must always supersede societal or religious morality when basic human rights are at stake. For GS Paper 1 and 2, this serves as a critical case study on gender justice and the role of the judiciary in facilitating social reform against regressive traditions.
Legal
The formation of a massive nine-judge bench highlights the immense constitutional weight of this issue, guided by , which mandates a minimum of five judges for cases involving substantial questions of constitutional interpretation. Interestingly, the expanded the scope of this review beyond Sabarimala to frame broader legal questions regarding women's entry into mosques, Parsi women's rights after inter-faith marriages, and female genital mutilation in the Dawoodi Bohra community. This unusual move—referring larger questions of law during a review petition—has sparked significant legal debate about the boundaries of the court's review jurisdiction. Aspirants should note how the judiciary is attempting to establish uniform, secular principles of law that apply equally across all religious denominations in India.