Kantaru Rajeevaru v. Indian Young Lawyers Association: Expanding the Scope of Judicial Review in Religious Practices

Introduction

The case of Kantaru Rajeevaru v. Indian Young Lawyers Association Through Its General Secretary Bhakti Pasrija And Others is a landmark judgment delivered by the Supreme Court of India on May 11, 2020. This case primarily dealt with the constitutional validity of Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorization of Entry) Rules, 1965, which restricted the entry of women between the ages of 10 and 50 years into the Sabarimala Temple. The Indian Young Lawyers Association filed a writ petition challenging these restrictions, asserting that they violated fundamental rights enshrined in the Constitution of India.

Summary of the Judgment

The Supreme Court, in a majority decision (4:1), upheld the writ petition filed by the Indian Young Lawyers Association, declaring Rule 3(b) of the 1965 Kerala Rules unconstitutional. The Court held that the exclusion of women aged 10 to 50 from the Sabarimala Temple violated Article 25 of the Constitution, which guarantees the freedom of religion. Additionally, the Court concluded that the devotees of Lord Ayyappa do not constitute a separate religious denomination and thus cannot claim protections under Article 26. Consequently, the restrictive rule was declared ultra vires, meaning beyond the powers of the Kerala authorities.

Analysis

Precedents Cited

The judgment references several key cases that have shaped the interpretation of religious freedoms and judicial review in India:

Commr. v. Sri Lakshmindra Thirtha Swamiar of Sri Shirur Matt (1954): Addressed the role of courts in matters of essential religious practices.
Durgah Committee v. Syed Hussain Ali (1962): Focused on the admissibility of judicial interventions in religious customs.
M.K. Salpekar v. Sunil Kumar Shamsunder Chaudhari (1988): Discussed the interpretative role of punctuation in statutory provisions.
Mohd. Shabir v. State Of Maharashtra (1979): Highlighted the significance of punctuation in legal interpretation.
Behram Khurshid Pesikaka v. State Of Bombay (1955): Emphasized the court's discretion in making references.
T.M.A. Pai Foundation v. State of Karnataka (2002) and K.S. Puttaswamy v. Union Of India (2017): Exemplified the Supreme Court’s approach to refer pure questions of law to larger benches.

Legal Reasoning

The Court's reasoning was multifaceted:

Constitutional Provisions: The judgment delved into Articles 25 and 26, elucidating the scope of religious freedom and the rights of religious denominations.
Judicial Review: A significant aspect was the Court's authority to refer questions of law to a larger bench, especially in matters where existing judgments presented conflicting interpretations.
Interpretation of Rules: The Court meticulously interpreted Order XLVII Rule 1 of the Supreme Court Rules, 2013, clarifying that limitations on review petitions do not extend to writ petitions under Article 32.

The Court emphasized that the inherent powers under Article 142 empower it to ensure justice, transcending procedural confines. By referring the case to a larger bench, the Court aimed to provide a definitive interpretation of constitutional provisions related to religious practices.

Impact

This judgment has profound implications for the Indian legal landscape:

Judicial Process: Reinforces the Supreme Court’s authority to refer complex legal questions to larger benches, ensuring thorough deliberation.
Religious Practices: Sets a precedent for challenging discriminatory practices within religious institutions, promoting gender equality.
Constitutional Law: Clarifies the interplay between Articles 25 and 26, assisting future cases in navigating religious freedoms and organizational rights.
Public Interest Litigation: Highlights the role of PILs in addressing societal issues, especially those intersecting with fundamental rights.

Complex Concepts Simplified

Articles 25 and 26:

Article 25: Guarantees freedom of conscience and the right to freely profess, practice, and propagate religion.
Article 26: Protects the rights of religious denominations to manage their own affairs in matters of religion.

Ultra Vires: A Latin term meaning "beyond the powers," used in law to describe acts conducted by government bodies that exceed the scope of power given to them by law. Judicial Review: The power of courts to assess whether a law or decision is in line with the constitution. Public Interest Litigation (PIL): A legal action initiated in the interest of the public, especially for addressing issues affecting the community or marginalized groups.

Conclusion

The Supreme Court's decision in Kantaru Rajeevaru v. Indian Young Lawyers Association serves as a pivotal moment in the adjudication of religious freedoms and gender equality in India. By affirming the unconstitutionality of gender-based restrictions in religious places of worship, the Court not only reinforced the principles of equality enshrined in the Constitution but also showcased the judiciary's proactive role in dismantling discriminatory practices. Furthermore, the judgment underscores the Supreme Court's expansive interpretative authority, particularly in matters involving fundamental rights and complex legal doctrines. As a precedent, this case will undoubtedly influence future litigations surrounding religious practices, gender rights, and the procedural dynamics of judicial reviews in India.