Between Equality and Religion: A Critical Analysis of the Indian Supreme Court’s Approach in the Sabarimala CaseIn Indian Young Lawyers Association v. State of Kerala (IYLA), the Supreme Court of India delivered a landmark ruling that declared the restrictions imposed on women’s entry into the Sabarimala Temple unconstitutional. This decision was widely hailed as progressive and transformative, advancing women’s right to equal access to places of worship. However, a closer examination of the judgment reveals a lack of substantive engagement with the principles of gender equality that have evolved over the years, despite the case being primarily concerned with gender-based discrimination. This article critically analyses the four separate opinions rendered in IYLA to illustrate how the Court focused more on issues of religious freedom than on those of equality and non-discrimination. It argues that the progressive outcome of the case was not sufficiently grounded in reasoning based on the right to equality under Articles 14, 15, and 17 of the Indian Constitution. Instead, the judgment predominantly rests on interpretations of the freedom of religion under Articles 25 and 26. As such, IYLA represents a missed opportunity to strengthen the Supreme Court’s gender equality jurisprudence, particularly in the context of religion. The Court’s approach reflects a broader concern that when gender equality intersects with religious freedom, the latter tends to overshadow the former.
Keywords
Sabarimala Temple Entry Case; Supreme Court of India; Gender Equality; Non-Discrimination; Freedom of Religion