INDIAN YOUNG LAWYERS ASSOCIATION V. STATE OF KERALA

Case Name: Indian Young Lawyers Association vs The State of Kerala

Citation: Writ Petition (Civil) No. 373 of 2006; AIRONLINE 2018 SC 243

Court: Supreme Court of India.

Date of Judgment: 28 September 2018.

Bench: Chief Justice Dipak Misra, Justice Rohinton F. Nariman, Justice A.M. Khanwilkar, Justice D.Y. Chandrachud and Justice Indu Malhotra.

PETITIONER: Indian Young Lawyers Association.

RESPONDENT: The State of Kerala.

INTRODUCTION.

Is it right to restrict women from entering a temple? This case arose from the long-standing practice of restricting women (between the ages of 10 and 50) from entering Sabarimala, a temple in Kerala. This restriction was solely based on the religious belief that Lord Ayyappa is a Naisthik Brahmachari, or a celibate deity.

The petitioners filed a case in the Supreme Court challenging this practice. In their opinion, the exclusion of women from those custom contravened fundamental rights, notably the right to equality, honour, and freedom of religion.

In that context, this case raised the principal question from the constitutional law standpoint: Should a religious custom be maintained when it is contrary to the fundamental rights guaranteed by the Constitution?

FACTS OF THE CASE

In Sabarimala temple, traditionally women between the ages 10-50 (who had attained puberty but had not reached menopause) were restricted from entering the temple. This practice has been followed for centuries as this practice has related to the belief that Lord Ayyappa at Sabarimala represent a celibate form. And according to this belief, women of menstruating age were not allowed to enter because their presence was considered inconsistent with the deity’s celibate nature and the religious traditions followed in the temple.

In the case of S. Mahendran v. Secretary, Travancore Devaswom Board, The Kerala High Court ruled in favour of the validity of such restriction on the entry of women. The Court held that existing custom was applicable in the case and thus did not violate Articles 15, 25 or 26 of the Constitution.

The Indian Young Lawyers Association challenged the ban at the Supreme Court seeking directions for allowing women of banned age to enter the temple and worship. The case also called into question the constitutionality of Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorization of Entry) Rules, 1965.

LEGAL ISSUES BEFORE THE COURT.

1. Whether the denial of entry to women into Sabarimala was contrary to Article 14, 15, and 17 of the Constitution.
2. Whether the denial was against Article 25 concerning the right to freedom of religion.
3. Whether the practice was an essential religious practice protected under Articles 25 and 26.
4. Whether the devotees of Lord Ayyappa constituted a separate religious denomination under Article 26.
5. Whether Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorisation of Entry) Rules, 1965 was unconstitutional and ultra vires the 1965 Act.
6. Whether religious freedom could prevail over constitutional values such as equality, dignity, and non-discrimination.

ARGUMENTS PRESENTED

PETITIONER’S ARGUMENT

1. This practice violated article 14, which guarantee equality before law.

2. The petitioners argued that the practice was a violation of Article 17 since regarding menstruating women as impure was equated with the concept of purity and pollution.

3. The exclusion contravened Article 21, especially the right to dignity of women.

4. According to Article 25(1), women are entitled to the same privileges as men intermsofthepractice of

5. The practice cannot be considered as a part of a majority religion, as the evidence provided by respondents does not support the idea that exclusion of women is an integral part of the religion.

6. IfweassumethatSabarimala is a religious denomination, the rights of Sabarimala under Article 26 shall not overrule the constitutional rights of the The petitioners contended that Rule 3(b) violates the purposes of the 1965 Act whichaims to ensure access to public places of worship for all classes and sections of Hindus.

RESPONDENTS ARGUMENT

The justifications offered by the respondents were largely stemmed from religious and cultural considerations.

Their argument was based on the claim that:

1. Sabarimala has a peculiar religious tradition linked to Lord Ayyappa’s standing as a Naisthik Brahmachari.

2. Accordingtothe religious practice, pilgrims are to conduct a 41-day Vrutham, whichrequiresahigh degree of spirituality and celibacy.

3. Itmerits of note that the ban on women aged between 11 and 50 isdirectlylinkedto the religious practice.

4. The practice has been deemed a matter of religious significance and thus protected under Article 25 and 26.

5. Rule 3(b) merely recognised an existing custom and usage of the temple.

6. The restrictions did not discriminate against women but were part of the uniqueness of the Sabarimala pilgrimage.

COURT’S REASONING AND ANALYSIS

The Supreme Court looked at the entire issue through the lens of constitutional equality and religious freedom.

• Right of Worship

The Court pointed out that Article 25(1) uses the expression “all persons.” Hence, the right to practice religion freely belongs both to men and women. The court ruled that this right could not be denied simply on the basis of gender and physical traits.

• Sabarimala Devotees are Not a Separate Religious Denomination

The Court analysed the concept of “religious denomination” in the context of Article 26 and referred to previous cases like Shirur Mutt and S.P. Mittal, whereby a religious denomination has to satisfy some criteria to be recognized as such: Common faith, Common organization, Distinctive name.

The court finally concluded that Ayyappa devotees do not form a separate religion but are actually part of the wider Hindu religion.

• It Was Not Necessary to Exclude Women

The Court deliberated on the matter of whether the exclusion of women aged 10-50 is an integral part of the religion.

The Court concluded that the materials produced by the respondents do not establish that the exclusion of women is a fundamental tenet of the religion. At best, it establishes that Lord Ayyappa is celibate, but it does not establish any link between celibacy and the exclusion of women. The Court also noted that there have been historical occasions when women of various ages visited Sabarimala. This inconsistency impacted the view that exclusion is mandated by the religion.

• Significance of Equality and Dignity

 the Court emphasized the significance of constitutional morality. It ruled out practices which are based on “purity and pollution” concepts because such practices are incompatible with the constitution whose focus is on dignity and equality.

• Article 25 and Article 26

The Court weighed up the individual rights to practice religion under Article 25 against the right of the religious denominations of Article 26.

The Court pointed out that religious freedoms cannot be deemed unlimited and subject to constitutional restrictions. In cases where a religious practice leads to the idea of exclusion and infringes upon the legal equality and dignity, the values of the Constitution should prevail.

• Rule 3(b)

The Court deliberated Rule 3(b) of the Rules of 1965. It found that the Legislative intention was to provide all Hindu communities with the right to enter the temples. Therefore, Rule 3(b) was declared to be ultra vires in so far as it allowed the exclusion of some Hindus.

JUDGMENT AND RATIO DECIDENDI

The writ petition was allowed by the Supreme Court. The majority opinion stated that the Lord Ayyappa followers do not form a distinct religious denomination and that women enjoy the same right under Article 25(1), which is given to men to profess their religion. Women’s exclusion between the age group of 10-50 years from the Sabarimala Temple violated their right to worship under the Constitution. The Court also stated that such exclusion cannot be treated as an essential religious practice and, instead, violates equality, dignity, and non-discrimination. Further, the Court also declared that Rule 3(b) is in breach of the 1965 Act. Thus, the writ petition was accepted.

RATIO DECIDENDI

The decision in the case can be summarized as stating that religious customs and practices cannot seek the benefit of constitutional protection if they infringe upon basic constitutional principles, such as the rights to equality and dignity. Women are “persons,” as per Article 25(1), and therefore entitled to equal religious rights. Any religious practice that denies women the right to practice religion because of their gender and sex can in no way qualify for protection just by being denominated as a religious practice.

CONCLUSION

The case known as Indian Young Lawyers Association v. State of Kerala is a historic case in terms of a clash between the doctrines of religious freedom and gender equality. In its ruling, the Supreme Court of India asserted that women cannot be banned from being in the public place of worship solely on the basis that they are women or due to any other biological differences.

The ruling contains a considerable emphasis on the fact that the Constitution should guarantee equality, dignity, and freedom of religion for all its citizens without any exception. Nevertheless, it becomes clear from the dissent opinion that the issue of the autonomy of religion is still complicated.

The case suggests that traditions and customs are supposed to operate in conformity with the Constitution. The importance of religious freedom cannot be used to justify any discrimination that goes against basic constitutional principles.

REFERENCE(S):

1. Justice C, “Indian Young Lawyers Association Vs the State of Kerala on 28 September 2018” (2018) <https://indiankanoon.org/doc/163639357/> accessed August 11, 2026
2. Law Bhoomi, “Case Brief: Indian Young Lawyers Association V. The State of Kerala [Writ Petition (Civil) No. 373 Of 2006]” (2022) <https://lawbhoomi.com/indian-young-lawyers-association-v-the-state-of-kerala/>
3. Jus Scriptum Editorial Board, “INDIAN YOUNG LAWYERS ASSOCIATION V. STATE of KERALA, 2018” (com, 2026) <https://www.jusscriptumlaw.com/blog/indian-young-lawyers-association-v-state-of-kerala-2018>
4. India SCO, “Indian Young Lawyers Association and Others V. State of Kerala and Others” (https://www.casemine.com, October 13, 2017) <https://www.casemine.com/judgement/in/59e1067cce686e237b6a8d78>