Source: Madras High Court 

Why in News? 

Recently, Justice Anand Venkatesh held that denying temple entry on the basis of caste is an affront to dignity and violates the rule of law, warranting action under the Tamil Nadu Temple Entry Authorisation Act, 1947. 

• The Madras High Court held this in the matter of Venkatesan v. The District Collector and Others. (2025). 

What was the Background of Venkatesan v. The District Collector and Others. (2025) Case? 

• This case originated from a petition filed by Venkatesan before the Madras High Court. The petitioner sought judicial intervention to secure temple entry and participation rights for members of his community at the Arulmigu Puthukudi Ayyanar Temple in Ariyalur district. 
• Venkatesan approached the court requesting directions to be issued to several authorities, including the District Collector of Ariyalur, the Revenue Divisional Officer, and the Assistant Commissioner of Hindu Religious and Charitable Endowments (HR&CE).  
• The specific relief sought was to permit members belonging to his community to participate in the temple car festival scheduled to be held at the temple. 
• The petitioner also sought permission for his community members to worship at the temple and conduct other religious rituals without any caste-based restrictions.  
• The case arose due to alleged discrimination preventing certain community members from accessing the temple and participating in religious festivities. 
• During the proceedings, the HR&CE Department informed the court that the particular temple in question was not under its administrative control or jurisdiction.  
• This clarification led to the court directing its orders specifically to the District Collector and Revenue Divisional Officer, who had territorial jurisdiction over the area. 

What were the Court’s Observations? 

• Justice Anand Venkatesh made several significant observations regarding caste-based discrimination in temple entry. The court observed that preventing individuals from entering temples based on their caste constitutes a serious affront to human dignity and cannot be tolerated in a nation governed by the rule of law. 
• The court noted that caste and community distinctions are human constructs, while divinity remains neutral and universal. The judge observed that restricting persons from offering prayers solely because they belong to Scheduled Caste communities represents a grave violation of their fundamental dignity. 
• The court emphasised that such discriminatory practices constitute an offence against the principles of equality and justice enshrined in the constitutional framework. The judge observed that no person should face restrictions in accessing places of worship based on their caste identity. 
• The court highlighted the provisions of Section 3 of the Tamil Nadu Temple Entry Authorisation Act 1947, observing that this legislation explicitly grants every Hindu, regardless of caste or sect, the right to enter Hindu temples and offer worship. The court noted that the Act provides for legal action against those who prevent such entry. 
• The court observed that this legislation was enacted following sustained struggles by various leaders who championed the cause of universal temple entry. The judge noted that the law was specifically designed to eliminate disabilities imposed on certain classes of Hindus regarding temple access. 
• The court directed that appropriate legal action should be taken against any person who prevents Scheduled Caste community members from participating in temple festivals, treating such acts as punishable offences under the law. 

What are the Legal Provisions Referred? 

Constitutional Provisions: 

• The right to equality under Article 14 of the Constitution of India, 1950 (COI) prohibits discrimination based on caste in accessing public places of worship. 
• Article 25 guarantees freedom of religion and the right to practice religious activities without caste-based restrictions. 
  • Article 25(1) gives people the freedom to practise, profess, and propagate their religion which is subject to public order, morality, and health.   
  • Article 25(2) allows the state to regulate economic, financial, political, or secular activities linked to religious practices and to enact laws for social welfare, reform, and opening Hindu religious institutions to all classes of Hindus.  
    • Hence, the issue of regulating secular aspects of religious practice is distinct from providing access to worship. 
• Article 17 of the Constitution abolishes untouchability and makes its practice in any form a punishable offence. 

Case Laws: 

Shirur Mutt v. Commissioner, Hindu Religious Endowments, Madras (1954): 

• Religious institutions have autonomous management rights under Article 26(d). 
• State can regulate religious institution administration within constitutional limits. 
• Established precedents for religious freedom and property rights protection. 

Ratilal Panachand Gandhi v. State of Bombay (1954): 

• Religious practices are integral parts of religion deserving constitutional protection. 
• Protection extends only to essential religious practices, not peripheral activities. 
• State can regulate administration of religious trust properties. 

Pannalal Bansilal Pitti vs. State of Andhra Pradesh (1996): 

• Upheld laws abolishing hereditary rights over temple management. 
• Religious reform laws need not apply uniformly across all religions. 
• Hereditary temple succession is not an essential religious practice. 

Stanislaus v. State of Madhya Pradesh (1977): 

• Right to propagate religion under Article 25 excludes right to convert others. 
• Upheld constitutional validity of anti-conversion laws. 
• Distinguished between spreading beliefs and coercive conversion.