Recently, the Madras High Court ruled that Article 25 and Article 26 of the Constitution protect only essential religious practices, not secular matters like temple administration. Dismissing a petition seeking caste-based control over a temple, the Court held that caste alone does not constitute a religious denomination and must align with constitutional principles.
The petitioner had approached the court seeking exclusive administration rights over a temple, asserting that only members of his caste had historically managed it. He argued that permitting individuals from other castes to participate in the administration would violate religious customs and traditions. The petitioner relied on constitutional provisions protecting religious freedoms to justify his claim.
The counsel for the petitioner contended that the temple in question had been historically managed by members of a specific caste, and any deviation from this practice would infringe upon religious rights. It was argued that such a restriction was an essential religious practice warranting constitutional protection under Article 25 and Article 26.
The Court, however, emphasised that the fundamental rights enshrined in Article 25 and Article 26 protect religious beliefs and practices but do not extend to secular affairs such as temple administration. It specifically observed that for a group to be recognised as a religious denomination under Article 26, it must fulfill three essential criteria: (i) it must have a common faith; (ii) it must adhere to a distinctive set of religious tenets; and (iii) it must be bound by a unique religious organisation. Mere caste affiliation does not meet these requirements.
The Court further noted that temple management, including the appointment of administrators, financial oversight, and governance, is a secular function that does not constitute an integral religious practice. It cited precedents to establish that only those practices that are essential to the core tenets of a religion qualify for constitutional protection, and not every practice historically followed by a group can be deemed essential. The Court clarified that restricting temple administration to a particular caste would violate the constitutional principles of equality under Article 14 and non-discrimination under Article 15.
In its decision, the High Court dismissed the petition, holding that the claim for caste-based temple administration lacked constitutional merit. It reaffirmed that religious freedoms must be balanced against the constitutional mandate to uphold equality and social justice. The Court concluded that the petitioner’s request was inconsistent with the secular fabric of the Constitution and, therefore, could not be upheld.
Case Title: C. Ganesan v. The Commissioner Hindu Religious and Charitable Endowments Administration & Anr.
Citation: W.P. No. 6704 of 2025
Coram: Justice D. Bharatha Chakravarthy
Advocate for Petitioner: Adv. T.S. Vijaya Raghavan
Advocate for Respondent: Adv. S. Ravi Chandran
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