Sabarimala case (Indian Young Lawyers’ Association v. State of Kerala): Judgement, Facts, Timeline
Sabarimala case: Judgement, Fact, Timeline of temple entry rights
The Sabarimala case has created not only a nation-wide debate over tradition, constitutional rights, and gender equality, but also raised the need to bring change in the age-old practice of not allowing women of menstruating age to enter Lord Ayyapa Shrine. The Sabrarimala case, also officially known as Indian Young Lawyers’ Association v. State of Kerala, is a landmark judgment by the Apex court on the entry of women into the temple. It is one of the major landmark cases which is asked in law entrance exams like AIBE, CLAT, AILET and others. It is important for aspirants to understand it completely to score well in the exam.
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Sabarimala is a major pilgrimage site for Lord Ayyappa in Kerala. For years, women of menstruating age have not been allowed temple entry in the name of Ayyappa’s celibate tradition. The restriction has been implemented based on the Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorisation of Entry) Rules, 1965. Indian Young Lawyers’ Association v. State of Kerala filed as a PIL, proclaiming that the custom and Rule 3(b) violate the equality and freedom of religion of women devotees. The constitutional validity of this rule and the important question of women’s right to enter in the temple, led to the landmark case: Indian Young Lawyers’ Association v. State of Kerala. Read further to know the facts, key arguments, Supreme Court observations, and judgment in detail.
Timeline of Sabarimala Case
To understand the case completely, it is important to know the exact timeline. Read below to get more details:
Pre-1991
For centuries, the Sabarimala Temple followed the tradition of not allowing the women of menstruating age (mostly 10-50 years) to enter the shrine. The tradition was justified by the temple authorities stating that the rule is based on the deity’s eternal celibacy (Naishtika Brahmacharya).
In 1965, the Kerala Hindu Places of Public Worship (Authorisation of Entry) Act was passed with the aim of opening temple doors for all Hindus, despite the class/category they belong to. However, Rule 3 (b) drafted under this Act allowed religious denominations to restrict entry of women as per the customs, hence giving a legal coverage for the Sabarimala practice.
Kerala High Court Judgment (1991)
In S. Mahendran v. The Secretary, Travancore Devaswom Board (1991), the Kerala High Court was questioned if women can enter the temple or not. However, the court backed the ban, stating that the restrictions on entry is an age-old custom and must be preserved. The Court also directed the Travancore Devaswom Board and the State of Kerala to impose the ban strictly. For almost two decades, this judgement was followed and treated as a settled law.
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PIL in the Supreme Court (2006)
In 2006, the Indian Young Lawyers’ Association and other petitioners approached the Supreme Court. They filed a Public Interest Litigation (PIL), arguing that restricting women between 10-50 years to enter the shrine violates their fundamental rights under Articles 14 (equality), 15 (non-discrimination), 17 (abolition of untouchability), and 25 (freedom of religion). This brought a major change in the complete outlook towards this case, making the debate from custom and belief to constitutional morality and gender justice.
Reference to Constitution Bench (2016)
After year of hearings, in 2016, the Apex Court referred the case to a five-judge Constitution Bench. This in turn reflected that the Supreme Court also considered the matter not only a temple issue but one raising substantial constitutional questions on religious freedom, gender equality, and the limits of judicial intervention in faith.
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The Landmark Supreme Court Judgment (2018)
A five-judge Bench of the SC on September 28, 2018, delivered the landmark judgement. The five-judge bench comprising of Former CJI Dipak Misra, Justice A.M. Khanwilkar, Justice D Y Chandrachud (Former CJI), Justice R F Nariman and Justice Indu Malhotra declared the exclusion of women unconstitutional. The Court held that Ayyappa devotees do not form a separate religious denomination under Article 26. Found Rule 3(b) of the 1965 Rules ultra vires and struck it down.
The Court further recognised women’s right to worship under Article 25(1), calling it an individual right that cannot be overridden by group claims. Justice Chandrachud further linked the practice to Article 17, arguing that exclusion on the basis of menstruation is a form of untouchability. Justice Malhotra argued that courts should not interfere in matters of faith. She said that the Sabarimala practice, though exclusionary, was protected as part of the community’s right under Article 26. While the verdict was celebrated massively among women’s rights groups, it also created widespread protests in Kerala, with traditionalists resisting its implementation.
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Review Petitions and Continuing Controversy (2019)
In 2019, several petitions were filed seeking review of the 2018 judgment. On November 14, 2019, a five-judge Bench by a 3:2 majority decided to not give a final ruling on the review. They kept the review petitions pending and referred larger constitutional questions on the interplay of religion, essential practices, and fundamental rights to a larger Bench.
Also, the Court did not put stay on the 2018 judgement. This means women’s entry remained legally permissible.
Nine-Judge Bench Reference (2020)
A nine-judge Bench of Supreme Court in February 2020 took up the larger reference. It framed seven broad legal questions, including:
- What constitutes an essential religious practice?
- To what extent can courts examine religious practices under Articles 25 and 26?
- How should courts balance individual rights vs. group rights in matters of religion?
However, due to COVID-19 pandemic the hearings was disrupted. Until now, no final decision on the larger issues have been delivered.
Current Status (2025)
The Supreme Court 2018 judgement is still operative law. The review petitions are still pending; the Court’s final verdict on the broader constitutional questions is awaited.
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