Sabarimala Case (2018) – Religion and Gender Equality

Sabarimala temple entry became one of the most closely watched fundamental-rights disputes of the last decade when a Constitution Bench of the Supreme Court, in 2018, held that women of all ages must be permitted to enter the Sabarimala temple in Kerala, striking down the practice that had barred women in the 10-to-50 age group. The case placed two constitutional values in direct tension — the freedom of a religious community to manage its own religious affairs, and the freedom of conscience and worship that Article 25 guarantees equally to every individual, including women.

Background: The Custom at Sabarimala

The Sabarimala temple, dedicated to Lord Ayyappa, had for long followed a custom excluding women in the reproductive age group — broadly, those between 10 and 50 years old — from entering the shrine, on the ground that the deity is worshipped in the form of a "Naishtik Brahmachari" (eternal celibate). This restriction was challenged as discriminatory and as a violation of the fundamental rights of women, setting up a direct constitutional confrontation between a claimed religious custom and the equality and freedom-of-religion guarantees in Part III.

What Article 25 Says

Article 25(1) provides that, subject to public order, morality and health and the other provisions of Part III, "all persons are equally entitled to freedom of conscience and the right freely to profess, practice and propagate religion." The critical word is "all persons" — the guarantee is not qualified by sex, age, or any other personal attribute. Article 25 rights are available to citizens and non-citizens alike, and are themselves subject to public order, morality, health, and the other fundamental rights provisions of Part III.

The Supreme Court's Holding

The Constitution Bench held that Article 25(1)'s freedom of conscience applies to all persons, including women, and that the exclusionary practice at Sabarimala violated Hindu women's right to practise their religion. The Court's reasoning rested on the principle that the right to practise religion is equally available to men and women of every age group — a custom that carves out an entire class of women from access to worship cannot be sustained as a reasonable restriction consistent with Article 25. The judgment accordingly required that the temple permit entry to women across all age groups, including the previously excluded 10–50 bracket.

Why It Was a Gender-Equality Case, Not Just a Religion Case

What made Sabarimala significant beyond its facts was that the Court read Article 25 through the lens of individual dignity and equal access to worship, rather than treating an exclusionary custom as automatically protected merely because it was long-standing or rooted in religious belief. The ruling reinforced that a religious practice restricting one sex's access to worship on grounds tied to biological attributes of women sits uneasily with the individual, non-discriminatory character of the Article 25(1) guarantee. This is why the case is studied not only under freedom of religion but also as a gender-equality precedent within the fundamental rights framework.

How It Fits with Articles 25–28

Article 25 protects the individual's freedom of conscience and worship; Article 26 separately protects the right of a religious denomination to manage its own religious affairs, institutions, and property, subject to public order, morality and health. Disputes like Sabarimala often sit at the intersection of these two articles — a religious institution's claim to manage its own affairs under Article 26 against an individual worshipper's claim to freedom of conscience and worship under Article 25. Articles 27 and 28 (freedom from religious taxation and freedom from compulsory religious instruction) address distinct concerns and were not the focus of this dispute.

UPSC Relevance

Prelims

• The Sabarimala case (2018) was decided by a Constitution Bench of the Supreme Court.
• The custom under challenge excluded women aged roughly 10 to 50 from temple entry.
• The Court held Article 25(1) applies equally to all persons, including women, and struck down the exclusion.

Mains

• Discuss how the Sabarimala judgment reconciles the individual freedom of conscience under Article 25 with claims of religious custom and denominational autonomy.
• "Freedom of religion under the Indian Constitution is an individual right, not a licence to discriminate." Examine with reference to the Sabarimala case.

FAQ

What did the Supreme Court decide in the Sabarimala case? A Constitution Bench held that women of all ages, including those in the 10–50 age group previously excluded, must be permitted entry to the Sabarimala temple, since Article 25(1)'s freedom of conscience applies equally to all persons.

Which article of the Constitution was central to the case? Article 25, which guarantees freedom of conscience and the right to freely profess, practise, and propagate religion to all persons, subject to public order, morality, and health.

Why is Sabarimala considered a gender-equality case? Because the excluded class was defined by attributes tied to women's biology, and the Court held that the right to practise religion is equally available to men and women of all age groups.

Does Article 25 protect religious customs even if they exclude a class of worshippers? Article 25 rights belong to individuals and are subject to the other provisions of Part III; a custom that denies access to worship to an entire class of persons on such grounds does not sit easily with the equal, individual character of the Article 25(1) guarantee, as the Sabarimala judgment illustrates.

Quick Revision

• Sabarimala case (2018): Constitution Bench of the Supreme Court.
• Issue: temple custom excluding women aged ~10–50 from entry.
• Holding: Article 25(1) freedom of conscience applies to all persons, including women; exclusion held to violate their right to practise religion.
• Principle: right to practise religion equally available to men and women of all age groups.
• Case sits at the intersection of individual freedom (Article 25) and denominational autonomy (Article 26).

Sources

• Constitution of India — Article 25, legislative.gov.in
• Supreme Court of India — official website

Further Reference

For deeper reading on this topic and the wider polity syllabus, these standard works are recommended:

• M. Laxmikanth, Indian Polity (McGraw Hill) — the standard UPSC handbook.
• D.D. Basu, Introduction to the Constitution of India (LexisNexis) — authoritative constitutional-law treatment.
• The Constitution of India — Bare Act — the official text.

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