Indian Young Lawyers Association and Ors. vs. The State of Kerala and Ors. [Sabarimala Temple Case]
Case Summary:
Indian Young Lawyers Association and Ors. v. The State of Kerala and Ors.
(2018) 11 SCC 1
Supreme Court of India
Decided on: September 28, 2018
Background / Facts:
The Sabarimala Temple in Kerala is a famous Hindu shrine dedicated to Lord Ayyappa.
The temple traditionally prohibited women of menstruating age (between 10 and 50 years) from entering its premises, based on religious customs.
The Indian Young Lawyers Association filed a Public Interest Litigation (PIL) challenging this ban as discriminatory and unconstitutional.
The petitioners argued that the restriction violated fundamental rights under the Indian Constitution — particularly:
Article 14 (Right to Equality)
Article 15 (Prohibition of discrimination on grounds of sex)
Article 25 (Freedom of religion), in its secular and non-discriminatory aspect.
The respondents (the State of Kerala, temple authorities, and others) contended that the ban was based on religious beliefs and customs protected under Article 25(1) and that the Court should not interfere in religious matters.
Legal Issues:
Whether the exclusion of women aged 10 to 50 years from entering Sabarimala Temple violated the right to equality and non-discrimination.
Whether the ban infringed on the fundamental right of women to freedom of religion.
Whether the Court could intervene in religious practices and customs.
Balancing the right to equality against the right to religious freedom.
Whether religious practices that discriminate against women can be allowed under the Constitution.
Judgment:
The Supreme Court delivered a historic 4:1 verdict with the majority ruling in favor of lifting the ban:
The Court held that the exclusion of women between 10 and 50 years of age from the temple was unconstitutional.
The practice was held to violate Article 14 (Right to Equality) and Article 15 (Prohibition of discrimination on the basis of sex).
The Court stated that the ban was not an essential religious practice protected under Article 25(1).
The court clarified that the Constitutional mandate overrides religious customs if they conflict with fundamental rights.
It was held that gender discrimination cannot be justified in the name of religion.
The Court emphasized women’s right to worship and access religious places on an equal footing.
The decision allowed women of all ages to enter the Sabarimala Temple.
However, the Court also acknowledged the importance of religion and custom, stating that courts should exercise restraint but will intervene when fundamental rights are violated.
Dissenting Opinion:
Justice Indu Malhotra dissented, holding that courts must not interfere with religious customs and that the ban was a matter of religious belief protected by Article 25.
She stressed that courts should not decide on religious doctrine and should respect the autonomy of faith communities.
Key Legal Principles:
1. Right to Equality and Non-Discrimination (Articles 14 & 15):
No person shall be discriminated against on grounds of sex.
Religious practices that violate these rights are subject to judicial review.
2. Freedom of Religion vs. Fundamental Rights:
Religious freedom is not absolute; it is subject to public order, morality, and health.
Practices contrary to fundamental rights cannot be shielded as religion.
3. Essential Religious Practices Doctrine:
Only practices that are essential to religion are protected under Article 25.
The Court found that the ban was not essential to Sabarimala’s religious beliefs.
4. Judicial Intervention in Religious Matters:
Courts can intervene if religious practices violate constitutional rights.
However, intervention should be cautious and respectful of religious sentiments.
Related Case Laws:
Shirur Mutt Case (1954) SCR 1005
Defined the “essential religious practices” test.
Rev. Stainislaus v. State of Madhya Pradesh (1977) 3 SCC 526
Affirmed limits on religious freedom in light of public order and morality.
Anuj Garg v. Hotel Association of India (2008) 3 SCC 1
Expanded protection against sex-based discrimination.
K.S. Puttaswamy v. Union of India (2017) 10 SCC 1
Right to privacy includes personal autonomy and dignity, relevant in gender equality cases.
Right to Privacy and Dignity Judgments
Courts increasingly affirm gender equality and individual autonomy as constitutional imperatives.
Significance:
This case is a milestone for women’s rights and gender equality in India.
It reinforced that fundamental rights supersede religious customs.
The verdict sent a strong message against gender discrimination cloaked in religion.
It sparked widespread debates on faith, tradition, and constitutionalism.
The case paved the way for greater inclusion of women in public religious life.
It reaffirmed the role of the judiciary as a protector of constitutional rights against discriminatory practices.
Summary in Simple Terms:
The Sabarimala Temple did not allow women aged 10-50 to enter, saying it was part of religious tradition.
Some people challenged this, saying it was unfair and against women’s rights.
The Supreme Court said the ban was unfair and unconstitutional because it treated women differently just because of their gender.
The Court allowed women of all ages to enter the temple.
It said religion is important, but not when it goes against equality and basic rights.
One judge disagreed, saying courts shouldn’t interfere with religion.
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