Context

• In September 2018, a five-judge Bench of the Supreme Court of India delivered its landmark judgment in Indian Young Lawyers Association vs State of Kerala, allowing women of all ages to enter the Sabarimala temple in Kerala.
• The ruling sparked nationwide debate and protests, especially in Kerala, reflecting tensions between religious autonomy and constitutional morality.
• At stake was not merely temple entry, but the deeper question of how a secular democracy reconciles faith, equality, and individual dignity.

Background of the Case

• The Practice in Question
  • The Sabarimala temple, dedicated to Lord Ayyappa, traditionally barred women between the ages of 10 and 50, citing the deity’s celibate nature and long-standing custom.
  • The exclusion was supported by Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorisation of Entry) Rules, 1965.
• The Majority Judgment
  • By a 4:1 majority, the Court held that:
    • Devotees of Lord Ayyappa did not form a separate religious denomination.
    • The exclusion violated women’s freedom of religion.
    • Rule 3(b) was unconstitutional and contrary to statutory guarantees of temple access.
  • The majority emphasized gender justice, non-discrimination, and the primacy of fundamental rights.
• The Dissenting Opinion: Justice Indu Malhotra’s Perspective
  • Justice Indu Malhotra’s dissent advanced a contrasting constitutional vision.
  • She argued that collective rights of religious communities must be harmonised with individual rights.
  • A broad principle of formal equality, she held, cannot override long-standing religious customs.
  • Central to her reasoning was the essential religious practice She viewed the exclusion as integral to the temple’s religious character and therefore constitutionally protected.

The Essential Religious Practices Doctrine

• Origins and Application
  • The essential religious practices (ERP) test empowers courts to determine whether a practice is fundamental to a religion.
  • If deemed essential, it receives protection under Articles 25 and 26; if not, the State may regulate it.
  • In Sastri Yagnapurushadji vs Muldas Bhudardas Vaishya (1966), the Court interpreted Hindu scriptures to define doctrinal essentials.
• Criticisms of the Doctrine
  • The ERP doctrine presents serious challenges:
  • It invites theological adjudication by secular courts.
  • It lacks procedural depth for resolving complex religious disputes.
  • It fails to resolve conflicts where an essential practice undermines human dignity.
  • By conditioning protection on judicial recognition of essentiality, the doctrine risks entrenching exclusionary practices.

The Anti-Exclusion Test: A Constitutional Alternative

• Conceptual Framework
  • To address these limitations, Justice D.Y. Chandrachud proposed the anti-exclusion test. This approach shifts the inquiry from theological necessity to constitutional impact.
  • Religious groups retain autonomy in defining their tenets, but practices that systematically exclude individuals in ways that impair dignity must yield to constitutional values.
  • The test focuses on whether exclusion restricts access to spaces central to civic or spiritual life and whether it violates equal moral membership.
• Key Distinction from the ERP Test
  • The distinction between the two approaches is foundational:
    • The ERP test asks whether a practice is essential to religion.
    • The anti-exclusion test asks whether its consequences are compatible with equality, liberty, and constitutional governance.
  • Under this framework, courts avoid doctrinal evaluation and instead assess the constitutional harm caused by exclusion.
  • The emphasis shifts from preserving tradition to safeguarding substantive equality.

Broader Constitutional Implications

• The principles emerging from Sabarimala extend beyond temple entry.
• Questions concerning the Dawoodi Bohra community’s practice of excommunication and the rights of Parsi women who marry outside the faith raise similar tensions between communitarian claims and individual conscience.
• India’s constitutional framework recognizes both religious freedom and the authority of denominations to manage their affairs.
• However, these rights are subject to public order, morality, and other fundamental rights.
• In a society, where religion shapes social identity, courts cannot ignore the real-world effects of exclusion.

Religion, Secularism, and Constitutional Morality

• The Indian Constitution envisions a model of principled secularism, neither hostile to religion nor subordinate to it.
• Religious belief remains protected, but its outward expression must align with the Constitution’s commitment to equal citizenship.
• The anti-exclusion approach affirms that faith is autonomous in doctrine yet accountable in practice.
• It reinforces the idea that no community can deny individuals access to institutions central to civic participation and spiritual life in the name of custom alone.

Conclusion

• The Sabarimala verdict represents a pivotal moment in Indian constitutional jurisprudence.
• It exposes the limitations of the essential religious practices doctrine and foregrounds the need for a dignity-centred framework.
• If the individual is the core unit of constitutional concern, then communitarian autonomy cannot override access to public religious spaces.
• By placing dignity, non-discrimination, and constitutional supremacy at the heart of the inquiry, the anti-exclusion test aligns religious freedom with the Constitution’s transformative vision.

About Tsomgo Lake:

• Tsomgo Lake, also known as Tsongmo Lake or Changu Lake, is a glacial lake located in East Sikkim.
• The lake derives its water from the melting snow of the mountains surrounding the lake.
• After the winter season ends in the middle of May, the periphery of the lake has scenic blooms of flower species of rhododendrons (the state tree of Sikkim), primulas, blue and yellow poppies, irises, and so forth.
  • Also seen in the precincts of the lake are several species of birds, including Brahminy ducks.
  • Wildlife seen includes the red panda.
• The lake surface reflects different colours with the change of seasons and is held in great reverence by the local Sikkimese
• Buddhist monks prognosticated after studying the changing colours of the lake.

About CM-302 Missile:

• It is a supersonic anti-ship cruise missile developed by China.
• It is an export version of the YJ-12 missile used by the Chinese Navy.
• It is intended to strike large naval vessels and other maritime targets.
• Features:
  • It is equipped with a liquid direct-flow air-breathing jet engine and four air intakes.
  • The missile travels at sustained supersonic speeds, reportedly around Mach 2.5–3 or higher, making it very hard and challenging to intercept once launched.
  • It has a range of about 290 km.
  • It is equipped with a conventional high-explosive warhead.
  • It can be launched from both ships and ground-based launchers.
  • The CM-302 approaches its target at extremely low altitudes.
  • The guidance system of the missile combines inertial navigation with China’s BeiDou satellite navigation for mid-course guidance, along with an active radar seeker for terminal homing.
  • It has a high hit probability, nearly 90 percent, owing to its sea-skimming flight profile and advanced guidance suite.

About Jeju Island:

• It is a volcanic island off the coast of South Korea.
• It is a special autonomous province of South Korea.
• Oval in shape, it is Korea’s largest and southernmost island.
• The provincial capital is the city of Jeju.
• It is composed of a core of volcanic material that rises symmetrically to the crest of Mount Hallasan, which has a lake in its crater.
  • Mount Hallasan is the tallest mountain in South Korea and a dormant volcano.
• The island’s lava tubes and certain other volcanic formations (including Mount Hallasan) were collectively designated a UNESCO World Heritage site in 2007.
• Jeju is bathed in warm currents, and its oceanic climate supports some subtropical plants.

About Capsid:

• A capsid is a three-dimensional proteinaceous capsular shell around a virus that encloses the viral genetic material.
• It is located just below the viral envelope.
• The capsid is made of several repeating finite numbers of protein subunits known as capsomeres or protomers.
• The capsomeres of the protein coat can be associated with or may be closely related to the viral genetic material or nucleic acid.
• The complexity of the capsid is dictated by the virus’s own genetic material. The more complex the genome, the more intricate the protein shell must be.
• Some complex viruses have capsids with non-protein components like lipids, or in certain viruses, the capsid is further enclosed in a glycoprotein layer; such capsids are known as enveloped capsids.
• The viral capsid is in the nanometer (nm) size range and possesses complex and unique mechanical properties.
• It serves multiple functions, namely, encapsulating and protecting viral genetic material and transferring of genetic material to the required place in the new host.
• For serving all these functions, the capsid needs highly specific mechanistic and functional flexibility as well as strength.

About Human Papillomavirus (HPV):

• HPV is the most common sexually transmitted infection (STI).
• More than 95% of cervical cancer is caused by the HPV virus.
• Transmission:
  • The virus that causes HPV infection is transmitted through skin-to-skin contact.
  • Most people get a genital HPV infection through direct sexual contact, including vaginal, anal, and oral sex.
• Treatment:
  • There’s no cure for HPV.
  • HPV vaccination is the most effective way to prevent HPV-related cancers.

HPV Vaccination:

• The HPV vaccine is a series of shots that can protect from an HPV infection.
• The HPV vaccination is more efficacious if given between the age group of 9-26 years.

About Periyar Tiger Reserve:

• Location: It is located in the Idukki district of Kerala.
• It is named after the Periyar River.
• It is set high at Cardamom Hills and Pandalam Hills of the Western Ghats, adjacent to the border with Tamil Nadu.
• It surrounds the Periyar Lake.
• Terrain: The terrain is hilly and undulating and the highest peak is Kottamala (2016 m).
• Rivers: Two major rivers namely Periyar and Pamba drain the area.
• Dams: Mullaperiyar Dam is located within the PTR. 
• Tribes: It is home to many tribal communities, including the Mannans and the Palians.
• Vegetation: It mainly comprises tropical evergreen forests, semi- evergreen forests, moist deciduous forests, transitional fringe evergreen forests, grasslands, and eucalyptus plantations.
• Flora: Teak, mangoes, rosewood, jamun, jacarandas, terminalias, tamarind, royal ponciana, bamboo, etc.
• Fauna: Elephants, Wild Pigs, Mouse Deer, Barking Deer, and Tiger.
  • The major four species of primates are also found at Periyar – the rare lion-tailed macaque, the Nilgiri Langur, Gee’s Golden Langur, Common Langur, and Bonnet Macaque.
  • It is also being considered as the habitat of the elusive Nilgiri Tahr.