The decision of the Supreme Court of India to commence substantive hearings before a nine-judge Constitution Bench on issues arising from the Sabarimala Temple entry case marks a pivotal moment in India’s constitutional jurisprudence. The controversy, which began with the 2018 judgment allowing entry of women of menstruating age into the temple, has evolved into a larger constitutional debate concerning the scope of religious freedom, the doctrine of essential religious practices, judicial intervention in matters of faith, and the relationship between equality and tradition. For aspirants of UPSC, SSC and State PCS examinations, this issue is of high relevance because it touches upon multiple provisions of the Constitution and tests the balance between fundamental rights.
The Sabarimala temple, dedicated to Lord Ayyappa, historically restricted the entry of women between the ages of 10 and 50, citing the celibate nature of the deity. In 2018, a five-judge Constitution Bench of the Supreme Court struck down this exclusion, holding that it violated constitutional guarantees of equality and non-discrimination. The majority judgment emphasized that practices based on biological factors cannot override the principles of dignity and equal citizenship. The Court invoked Articles 14 and 15, which guarantee equality before law and prohibit discrimination on grounds of sex, along with Article 25, which ensures freedom of religion.
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The 2018 verdict was widely debated across the country. Supporters hailed it as a milestone in gender justice, while critics argued that the Court had interfered with a long-standing religious tradition. Following the judgment, numerous review petitions were filed. In 2019, the Court decided to refer broader questions concerning essential religious practices and the judiciary’s role in religious matters to a larger bench. The nine-judge bench is now expected to examine these constitutional issues in depth.
At the heart of the dispute lies the doctrine of “essential religious practices.” This doctrine emerged from earlier Supreme Court judgments, notably the Shirur Mutt case of 1954, in which the Court held that only those practices essential to a religion are protected under Article 25. Over the decades, courts have often examined religious texts and traditions to determine whether a particular practice qualifies as essential. Critics argue that this approach places judges in the position of theological interpreters, potentially leading to judicial overreach. The Sabarimala reference provides an opportunity for the Court to reconsider or refine this doctrine.
The constitutional provisions involved in this case are central to Indian polity. Article 14 guarantees equality before law and equal protection of laws. Article 15 prohibits discrimination on grounds of religion, race, caste, sex or place of birth. Article 25 ensures freedom of conscience and the right to freely profess, practice and propagate religion, subject to public order, morality and health. Article 26 grants religious denominations the right to manage their own affairs in matters of religion. The interplay between these provisions forms the crux of the Sabarimala debate.
The 2018 majority judgment emphasized the concept of constitutional morality. This idea suggests that constitutional values such as liberty, equality and dignity must prevail over social or religious norms that infringe upon fundamental rights. The Court reasoned that exclusion of women solely on biological grounds undermines their dignity and equal status. However, dissenting opinions cautioned against excessive judicial intervention in matters of faith and emphasized respect for denominational autonomy.
The nine-judge bench is not limited to Sabarimala alone. It is also expected to address similar issues arising in other cases involving religious practices and gender equality. Therefore, its ruling may have far-reaching implications for future disputes concerning temple entry, mosque practices and other religious customs. The judgment could redefine the scope of Article 25 and clarify the limits of judicial review in religious matters.
From a governance perspective, the case highlights the tension between majoritarian sentiment and constitutional safeguards. In a diverse and plural society like India, religious traditions vary widely. The Constitution protects religious freedom but also mandates equality and social reform. Article 25(2) specifically allows the state to enact laws for social welfare and reform, even if such laws interfere with religious practices. The Sabarimala issue tests the extent to which courts can advance social reform while respecting religious autonomy.
The case also reflects the evolving understanding of gender justice in India. Over the years, the Supreme Court has delivered landmark judgments expanding women’s rights in areas such as triple talaq, inheritance and workplace equality. The Sabarimala decision fits within this broader judicial trend of promoting substantive equality. However, the review proceedings indicate that constitutional questions remain unsettled, particularly regarding how courts should balance equality with religious identity.
For UPSC aspirants, this topic is extremely important for General Studies Paper II, especially under themes such as fundamental rights, role of judiciary, separation of powers and constitutional interpretation. It is also relevant for essay preparation on themes like “Gender Justice in India,” “Constitutional Morality versus Social Morality,” and “Judicial Activism and Judicial Restraint.” Understanding landmark cases, constitutional articles and doctrines such as essential religious practices is essential for writing analytical answers.
The broader democratic significance of the Sabarimala review lies in its potential to shape India’s constitutional identity. The Constitution envisions a secular state that neither favors nor discriminates against any religion. Secularism in India implies principled distance rather than strict separation. The judiciary plays a crucial role in maintaining this balance. Its decisions must uphold fundamental rights while avoiding unnecessary intrusion into theological matters.
Another dimension concerns the legitimacy of judicial authority. When courts enter deeply contested cultural and religious spaces, public acceptance of their decisions becomes critical. Implementation challenges following the 2018 verdict demonstrated how judicial pronouncements can face resistance on the ground. The review process therefore provides an opportunity for the Court to articulate principles that are both constitutionally sound and socially sustainable.
In conclusion, the Sabarimala review before the nine-judge bench represents a defining constitutional moment. It encapsulates the complex relationship between faith and fundamental rights, equality and tradition, judicial intervention and democratic legitimacy. The Supreme Court’s forthcoming interpretation will not only resolve doctrinal ambiguities but also influence the trajectory of gender justice and religious freedom in India. For competitive examination aspirants, the case offers a comprehensive study of constitutional law, governance and evolving democratic values, making it an indispensable topic for preparation.