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Supreme Court to Re‑hear Sabarimala Verdict: Anti‑Exclusion Test vs Essential Religious Practices — UPSC Current Affairs | February 26, 2026
Supreme Court to Re‑hear Sabarimala Verdict: Anti‑Exclusion Test vs Essential Religious Practices
The Supreme Court will rehear review petitions on its 2018 Sabarimala verdict, pitting the traditional essential‑religious‑practice test against Justice Chandrachud's proposed anti‑exclusion test. The outcome will shape how Indian jurisprudence balances religious autonomy with individual dignity, a key issue for UPSC Polity and Ethics.
Overview The nine‑judge Supreme Court will soon hear review petitions seeking to overturn its 2018 judgment that opened the Sabarimala Temple to women of all ages. The case pits the traditional essential religious practices test against a newly proposed anti‑exclusion test , raising profound questions about religious freedom and gender equality. Key Developments 2018 verdict delivered by a 4:1 majority, with Justice Indu Malhotra dissenting, upheld women’s right to enter Sabarimala. Majority held that the ban violated fundamental rights and that the temple was not a separate denomination. Justice D.Y. Chandrachud later suggested the anti‑exclusion test to balance religious autonomy with individual dignity. Review petitions filed by the Indian Young Lawyers Association aim to reinstate the age‑based restriction. The nine‑judge bench will examine the broader architecture of India’s religious‑freedom clauses. Important Facts The 2018 judgment rested on three findings: (1) devotees of Lord Ayyappa are not a distinct religious denomination; (2) the ban on women aged 10‑50 infringed on the right to freedom of religion; and (3) Rule 3(b) of the 1965 Kerala Hindu Places of Public Worship Rules contravened the Constitution and the parent law guaranteeing free temple access to all Hindus. Justice Malhotra’s dissent argued that a “non‑derogable essential religious practice” can justify exclusion, emphasizing the need to harmonise individual rights with collective customs. UPSC Relevance This case illustrates the tension between individual liberty and communitarian rights , a recurring theme in GS‑2 (Polity). It also highlights judicial tools— the essential‑practice doctrine and the proposed anti‑exclusion test—used to interpret Articles 25‑28 of the Constitution. Understanding these doctrines aids answers on constitutional law, gender justice, and secularism. For GS‑1 (History & Culture), the Sabarimala controversy provides a contemporary example of how religious customs evolve under constitutional scrutiny. For GS‑4 (Ethics), the debate raises questions about the moral limits of state intervention in faith‑based practices. Way Forward If the bench adopts the anti‑exclusion test, future disputes—such as the excommunication of Dawoodi Bohra members or the rights of Parsi women marrying outside the faith—could be resolved by assessing whether a practice harms individual dignity rather than by judging its theological essentiality. This shift would align judicial review more closely with the Constitution’s liberal promise while preserving genuine religious autonomy. Conversely, a revival of the essential‑practice test could reaffirm the judiciary’s role as a theological arbiter, potentially limiting gender‑equality advances. Aspirants should monitor the bench’s reasoning, as it will set precedent for interpreting religious‑freedom clauses across India.
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Overview

Supreme Court’s re‑hear of Sabarimala tests anti‑exclusion vs essential‑practice doctrine, shaping religious‑freedom jurisprudence

Key Facts

  1. 2018 Sabarimala verdict delivered by a 4:1 majority, allowing women of all ages to enter the temple.
  2. Bench headed by Justice D.Y. Chandrachud, who later proposed the anti‑exclusion test.
  3. Justice Indu Malhotra dissented, upholding the “essential religious practice” defence for age‑based exclusion.
  4. Review petitions filed by the Indian Young Lawyers Association seeking to reinstate the 10‑50 age ban.
  5. Case invokes Articles 14, 15 and 25 of the Constitution and questions the denominational status of Ayyappa worship.
  6. Rule 3(b) of the 1965 Kerala Hindu Places of Public Worship Rules was struck down as unconstitutional.
  7. The nine‑judge bench will examine the broader architecture of India’s religious‑freedom clauses, setting precedent for future cases like Dawoodi Bohra excommunication.

Background & Context

The Sabarimala controversy sits at the intersection of constitutional law, gender justice and secularism—core components of GS‑2. It tests the judiciary’s role in interpreting Articles 14, 15 and 25, and illustrates the tension between individual rights and communal religious practices, a recurring theme in UPSC polity and ethics syllabi.

UPSC Syllabus Connections

Essay•Philosophy, Ethics and Human ValuesPrelims_GS•Constitution and Political SystemEssay•Society, Gender and Social JusticeGS2•Historical underpinnings, evolution, features, amendments, significant provisions and basic structurePrelims_GS•Public Policy and Rights IssuesGS4•Content, structure, function of attitude and its influence on behaviorGS4•Dimensions of ethics - private and public relationshipsGS4•Role of family, society and educational institutions in inculcating valuesGS4•Essence, determinants and consequences of Ethics in human actionsGS1•Social Empowerment, Communalism, Regionalism and Secularism

Mains Answer Angle

In a GS‑2 answer, candidates can analyse how the anti‑exclusion test could recalibrate the balance between religious autonomy and gender equality, possibly framing a question on "Judicial approaches to religious freedom in India".

Full Article

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Analysis

Practice Questions

Prelims
Easy
Prelims MCQ

Judicial doctrines on religious freedom

2 marks
4 keywords
GS2
Medium
Mains Short Answer

Constitutional interpretation of Articles 25‑28

10 marks
5 keywords
GS2
Hard
Mains Essay

Religion, gender justice and constitutional law

250 marks
7 keywords
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