Supreme Court Rules Caste‑Based Exclusion Not Religious – Parsi Woman’s Temple Entry Case

Supreme Court Clarifies that Caste‑Based Exclusion Cannot be Treated as Religious Practice On 5 May 2026 , the Supreme Court pronounced that any practice which excludes people on the basis of caste has no nexus with religion. The observation was made by Justice B.V. Nagarathna while hearing a petition linked to the Sabarimala review bench. Key Developments Justice Nagarathna stated that a "casteist" practice cannot be termed a religious practice and that Article 25 empowers the State to legislate against caste‑based discrimination in the name of religion. The petition was filed by senior advocate Darius J. Khambata on behalf of Goolrokh Gupta , a Parsi woman barred from the Agiari after marrying a Hindu under the Special Marriage Act . The case was referred to a nine‑judge Constitution Bench headed by Chief Justice of India Surya Kant , indicating its constitutional significance. Justice Nagarathna likened the exclusion of married Parsi women to "excommunication", highlighting gender‑biased application of religious norms. Important Facts The Gujarat High Court (23 March 2012) had held that Ms. Gupta ceased to be a Parsi after her inter‑faith marriage, a view supported by affidavits of seven Parsi priests. The petitioners argued that the Doctrine of Coverture is not recognised by the Indian Constitution and violates fundamental rights. They also contended that the Parsi (Zoroastrian) religion is forward‑looking and imposes no doctrinal ban on women offering prayers after inter‑faith marriage. UPSC Relevance This judgment touches upon several core areas of the UPSC syllabus: Constitutional Law (GS2) : Interpretation of Article 25 and the State's power to curb caste‑based discrimination. Social Justice (GS1/GS4) : Issues of caste discrimination, gender bias in religious practices, and protection of minority rights. Legal Framework (GS2) : Role of the Supreme Court , Constitution Bench, and the interplay between personal laws and civil statutes like the Special Marriage Act . Way Forward Legal scholars suggest that the Court may either: Declare the exclusion of married Parsi women from the Agiari unconstitutional, thereby reinforcing gender equality under Article 25 . Prompt the Parsi community to amend its internal bylaws, aligning religious customs with contemporary constitutional values. Encourage legislative action to protect minority religious practices while ensuring they do not perpetuate caste or gender discrimination. For UPSC aspirants, monitoring the outcome will provide insight into how Indian jurisprudence balances religious freedom with social justice, a recurring theme in both the prelims and mains examinations.