Indian Young Lawyers Association & Ors. v. The State of Kerala & Ors. (Sabarimala Temple Entry Case)
Background
The Sabarimala Temple in Kerala, dedicated to Lord Ayyappa, traditionally barred entry to women between the ages of 10 and 55 (menstruating age), based on Rule 3(b) framed under the Kerala Hindu Places of Public Worship (Authorisation of Entry) Act, 1965, and a custom said to flow from the deity's status as an eternal celibate. The Indian Young Lawyers Association and others filed a writ petition arguing this exclusion violated women's fundamental rights to equality, non-discrimination, and freedom to practise religion, while the temple's authorities and worshippers argued the practice was an essential religious custom protected by their denominational rights under Article 26.
Decision Breakdown
By a 4:1 majority, the Supreme Court held that the exclusion of women aged 10-55 from the Sabarimala Temple was unconstitutional. The majority (CJI Misra and Justice Khanwilkar in a joint opinion, with Justices Nariman and Chandrachud writing separately) held that devotees of Lord Ayyappa do not constitute a separate religious denomination entitled to special protection under Article 26, that the exclusion is not an essential religious practice integral to the faith, that it amounts to unconstitutional discrimination based on a biological characteristic unique to women, and that Rule 3(b) is ultra vires (beyond the powers granted by) both the parent 1965 Act and the Constitution. Justice Indu Malhotra dissented, holding that the issue was non-justiciable given the petitioners' lack of personal grievance, that constitutional morality requires harmonising equality with the denomination's own right to manage its religious affairs, and that the restriction did not amount to untouchability under Article 17. The majority allowed the writ petition and struck down the restriction, with no order as to costs.
Lesson Learnt
A religious practice that discriminates against women on grounds that are not shown to be an essential, integral part of the faith cannot shelter behind religious freedom or denominational rights if it conflicts with constitutional guarantees of equality and dignity, but this landmark 4:1 ruling itself provoked massive public protest and was later revisited by a larger nine-judge bench on related questions of law, illustrating that even top-court constitutional rulings on deeply contested social practices can remain legally and socially unsettled long after they are pronounced.