Indian Young Lawyers Association v. State of Kerala

Quick Summary

The case is about women’s entry to Sabarimala temple. A long-standing custom blocked women aged 10–50 from entering. Petitioners said this is discrimination. The State and temple side said it is part of faith.

By a 4–1 majority, the Supreme Court held the ban unconstitutional. It violated equality (Articles 14, 15), dignity and freedom of religion of women (Article 25(1)). Rule 3(b) that enabled exclusion was also struck down.

Issues

1. Does a biological factor linked to women justify exclusion under Articles 25–26, or is it discrimination under Articles 14, 15, and 17?
2. Is Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorization of Entry) Rules, 1965 valid?

Rules

• Article 14: Equality before law; no arbitrary discrimination.
• Article 15: No discrimination on sex, etc.
• Article 17: Bans untouchability-like exclusionary practices.
• Article 25: Freedom of religion for all persons, subject to constitutional morality and other rights.
• Constitutional Morality: Harmonises rights so custom cannot defeat equality and dignity.

Arguments

Judgment (Held)

• Ban unconstitutional (4–1): Violates Articles 14, 15, 19(1), 21, 25(1).
• Rule 3(b) invalid: Cannot authorise exclusion of women from public worship.
• Constitutional morality guides interpretation—equal dignity and access to worship for women.

Ratio Decidendi

A sex-based exclusion, justified by custom, fails equality and dignity. Fundamental rights are individual-centric; custom cannot cancel a woman’s right to worship. State-made rules (like Rule 3(b)) cannot permit practices that breach the Constitution.

Why It Matters

• Sets a strong standard for gender equality in religious spaces.
• Explains constitutional morality as a tool to balance equality and faith.
• Limits the use of custom to justify exclusion in public worship.

Key Takeaways

• Equality + Dignity trump exclusionary custom.
• Individual rights in Article 25 include women’s right to worship.
• Rules enabling discrimination (like Rule 3(b)) cannot stand.

Mnemonic + 3-Step Hook

Mnemonic: “Door to Dignity”

1. Door: Temple doors are public—access can’t be shut by sex.
2. To: Articles 14 & 15 steer the law.
3. Dignity: Article 25 protects worship for all persons.

IRAC Outline

Glossary

Constitutional Morality

A standard that keeps all rights in balance—custom can’t defeat equality.

Public Worship

Worship in temples open to the public; access rules must meet constitutional tests.

Rule 3(b)

A 1965 rule that allowed exclusion by custom—struck down in this case.

FAQs

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