On the Sabarimala temple entry case

The core constitutional conflict in this case revolves around the friction between the right to equality and non-discrimination (Article 14 and Article 15) versus the freedom to manage religious affairs (Article 26). In 2018, the court held that devotees of Lord Ayyappa do not constitute a distinct religious denomination under Article 26, thereby denying them absolute autonomy to exclude women based on custom. Furthermore, the judiciary heavily relied on the doctrine of Essential Religious Practice—first established in the 1954 Shirur Mutt Case—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.

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 Article 21. 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.

The formation of a massive nine-judge bench highlights the immense constitutional weight of this issue, guided by Article 145(3), which mandates a minimum of five judges for cases involving substantial questions of constitutional interpretation. Interestingly, the Supreme Court 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.