Dr. G. Mohan Gopal, representing the Sree Narayana Manava Dharmam Trust, urged the Supreme Court nine‑judge bench hearing the Sabarimala reference to create constitutional space for internal reformist movements. He warned that the prevailing judicial interpretation of Article 25 has, for seventy‑five years, muted voices seeking social justice from within religious communities.
Key Developments
- Gopal highlighted the need to view religious freedom not merely as a clash between Part III rights and the rights of denominations under Article 26, but also as a platform for social‑justice demands emerging from within faith traditions.
- He cited 19th‑century reformers like Sri Narayana Guru to argue that internal reformist traditions should be protected by the Constitution.
- Chief Justice Justice Surya Kant noted that internal reform would also fall under Article 25.
- Justice BV Nagarathna emphasized that Hinduism can be understood as a “way of life,” allowing individuals to be religious without formal rituals.
- Gopal warned that an overly broad interpretation of denominational rights could let any group claim immunity from Part III guarantees.
Important Facts
The Trust’s written submission draws on a 1947 document by Dr. B.R. Ambedkar to the Constituent Assembly, noting that the draft omitted the word “practice” from the freedom of religion clause – a deliberate omission reflecting concerns about oppression within religious structures. It also challenges the 1966 Swami Yagnapurushdasji judgment that defined a Hindu solely by acceptance of the Vedas, arguing that such a monolithic definition ignores the diversity of belief among Hindus.
Both Justices underscored that religiosity can exist without temple visits or prayer rooms, reinforcing the idea that individual conscience, not clerical authority, is the core of religious freedom.
Exam Relevance
Understanding the tension between constitutional morality and traditional religious doctrines is essential for GS‑2 (Polity) questions on fundamental rights, secularism, and the role of the judiciary. The case illustrates how the Supreme Court balances Article 25 with gender‑equality concerns, a recurring theme in recent UPSC essays.
Moreover, the discussion on Article 26 versus individual rights helps aspirants analyse the limits of religious autonomy, a frequent topic in constitutional law papers.
Way Forward
The Trust urges the Court to recalibrate the interpretive framework of religious freedom, ensuring that internal reformist voices are not silenced and that any restriction on religious practice must be justified by legislation, not clerical decree. It calls for a reading of Article 25(2)(b) that embraces social‑reform mandates, thereby aligning religious liberty with the Constitution’s egalitarian ethos.
For UPSC candidates, the case underscores the need to evaluate constitutional provisions not as isolated clauses but as part of an integrated framework that safeguards individual conscience while permitting reasonable state regulation.