The Sabarimala verdict is the Indian Supreme Court’s September 28, 2018 ruling that struck down the ban on women aged 10 to 50 entering the Sabarimala Temple in Kerala. By a 4-1 majority, a five-judge Constitution Bench held that excluding women of menstruating age violated the constitutional guarantees of equality and religious freedom, and it declared Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorisation of Entry) Rules, 1965 unconstitutional. That ruling remains the operative law today, though a nine-judge bench reserved judgment on May 14, 2026 in a review that could reshape how Indian courts weigh religious practices against individual rights.
The Ban the Court Struck Down
Sabarimala, in the hills of Kerala, is one of India’s most visited pilgrimage sites and is dedicated to Lord Ayyappa. Temple tradition treats Ayyappa as a celibate deity, and on that basis women roughly between the ages of 10 and 50 were kept out for generations.
In 1991 the Kerala High Court gave the custom legal force, upholding the restriction by reference to the celibate character of the deity.1Wikipedia. Entry of Women to Sabarimala The statutory anchor was Rule 3(b) of the 1965 Kerala rules, which permitted religious authorities to exclude women from temples where custom or usage barred their entry.2Supreme Court Observer. Indian Young Lawyers’ Association v State of Kerala The ban stood for 27 years before the Supreme Court took it up.
What the 2018 Majority Held
The petition originated in 2006, filed by the Indian Young Lawyers Association, and reached a five-judge Constitution Bench that ruled 4-1 against the ban.3Indian Kanoon. Indian Young Lawyers Association vs The State of Kerala Each majority judge wrote separately, but their reasoning converged.
Chief Justice Dipak Misra, writing for himself and Justice A.M. Khanwilkar, held that Ayyappa devotees are Hindus and do not constitute a separate religious denomination entitled to exclude anyone. He also found that barring women of a particular age was not an essential religious practice deserving constitutional protection.4Supreme Court Observer. Sabarimala Temple Entry – Judgement Summary
Justice Rohinton Nariman wrote that denying entry rendered women’s right to worship meaningless. Justice D.Y. Chandrachud went further, invoking Article 17 of the Constitution, which prohibits untouchability. He argued that untouchability should be read expansively to cover the social exclusion of women based on notions of purity and pollution tied to menstruation.4Supreme Court Observer. Sabarimala Temple Entry – Judgement Summary That framing linked gender-based temple exclusion to India’s constitutional commitment against caste-like discrimination.
The Constitutional Reasoning
The majority built its decision on interlocking provisions. Article 14 guarantees equality before the law. Article 15 prohibits discrimination on grounds including sex and religion. Together they made it difficult for the court to accept that biological characteristics could justify denying a class of citizens access to a public religious space.1Wikipedia. Entry of Women to Sabarimala
Article 25(1) states that “all persons are equally entitled to freedom of conscience and the right freely to profess, practise and propagate religion,” subject to public order, morality, and health.5Indian Kanoon. Article 25 in Constitution of India The majority read this as guaranteeing women the same spiritual access as men. Because the restriction targeted only women of a specific age range, the court treated it as a denial of their individual right to worship rather than a protected expression of temple tradition.
Why the Denomination Defense Failed
Temple authorities relied on Article 26, which protects the right of religious denominations to manage their own affairs. Their argument was that Ayyappa devotees form a distinct denomination whose practices include excluding women of menstruating age. If accepted, that framing would shield the exclusion from equality-based challenges.
The court rejected it. Under a three-part test from earlier cases, a group qualifies as a religious denomination only if it has a distinct system of beliefs, a common organization, and a distinctive name.6Indian Kanoon. S.P. Mittal Etc. Etc vs Union of India and Others The bench concluded that Ayyappa devotees are part of the broader Hindu faith and did not satisfy those criteria. Without denomination status, the Article 26 defense collapsed.
The Essential Religious Practices Test
Indian courts use the “Essential Religious Practices” doctrine to decide which customs deserve constitutional protection. The doctrine asks whether a practice is truly integral to the religion in question.7Supreme Court Observer. Essential Religious Practices – Court in Review The Sabarimala majority applied it and concluded that excluding women was not essential to Hindu worship at the temple. That conclusion is precisely what the nine-judge bench is now reconsidering, because the test itself has been criticized for giving judges the power to decide what counts as essential to someone else’s religion.
Justice Malhotra’s Dissent
Justice Indu Malhotra was the sole dissenter, and her opinion cut against the majority on nearly every point.4Supreme Court Observer. Sabarimala Temple Entry – Judgement Summary She argued that courts should not be deciding which religious practices are essential and which are not; that determination, in her view, belongs to the religious community itself. Applying a rationality test to matters of faith risked setting a precedent that could threaten minority religions with less political power than Hinduism.
Malhotra also challenged the standing of the petitioners. The Indian Young Lawyers Association was not a group of Ayyappa devotees but outsiders to the faith seeking to change its internal practices. She questioned whether public interest litigation brought by people unconnected to a religious tradition should be the vehicle for overturning that tradition’s customs. The concern about PIL standing was later included among the questions referred to the nine-judge bench.
What Happened After the Verdict
The ruling triggered some of the most intense social upheaval Kerala had seen in years. Protests engulfed the state through the 2018-2019 pilgrimage season, with demonstrators blocking roads and confronting police to prevent women from reaching the temple.
On January 2, 2019, two women in their forties, Bindu Ammini and Kanakadurga, became the first women of reproductive age to enter the Sabarimala sanctum after the verdict. Temple authorities briefly closed the shrine for a “purification” ceremony. The entry sparked a statewide shutdown, reports of violence, and travel advisories from airlines operating in Kerala. Both women faced sustained harassment and threats, and the Supreme Court eventually ordered the Kerala government to provide them with security.8Wikipedia. Bindu Ammini
On January 1, 2019, a coalition of 176 social and political organizations, backed by the Kerala state government, organized the Vanitha Mathil, or Women’s Wall. Millions of participants formed a human chain stretching roughly 385 miles across the state in support of the verdict.
The Review and the Nine-Judge Referral
Dozens of review petitions were filed almost immediately. In November 2019 a five-judge review bench split 3-2 on how to proceed. Rather than reversing or affirming the 2018 decision, the majority kept the review petitions pending and referred seven broader constitutional questions to a larger bench.9Supreme Court Observer. Sabrimala Review – Judgment Summary Critically, the bench stated that the 2018 judgment would remain enforceable until the review was decided.2Supreme Court Observer. Indian Young Lawyers’ Association v State of Kerala
The referred questions reach well beyond Sabarimala. They ask how courts should balance religious freedom under Articles 25 and 26 against the equality guarantee in Article 14; whether “morality” in Article 25(1) means constitutional morality or the moral standards of a particular faith; how far a court can go in deciding what counts as an essential religious practice; whether essential practices of a religious denomination receive independent constitutional protection; and whether people outside a religious community can use public interest litigation to challenge that community’s practices. A broad ruling on the essential practices doctrine could reshape how courts handle disputes over Muslim personal law, Parsi customs, or Sikh religious governance, which is why the bench was expanded to nine judges.
Where the Case Stands in 2026
After years of delay, the nine-judge bench convened for oral arguments in April 2026 and reserved judgment on May 14, 2026 after 16 days of hearings.10Supreme Court Observer. Sabarimala Review No date has been announced for the judgment.
Until the nine-judge bench delivers its ruling, the 2018 verdict remains the operative law, and women of all ages are legally entitled to enter the Sabarimala Temple. In practice, social and political resistance has made that right difficult to exercise. The eventual ruling will settle more than the Sabarimala question; it will establish constitutional principles governing the relationship between religious autonomy and individual rights across Indian faiths.