Examine the tension between Article 25(2)(b) and Article 26 in ensuring non-discriminatory access to places of worship.

Article 25(2)(b) lets the State throw open Hindu religious institutions of a public character to all classes and sections of Hindus. Article 26(b) lets every religious denomination manage its own affairs in matters of religion [1]. Temple access lies where the State's power of reform meets a denomination's autonomy.

Sources of the tension

• Who decides entry: the Supreme Court has held that who may enter a temple, and where they may stand, are "matters of religion" under Article 26(b) [2].
• Reform mandate: Article 25(2)(b), read with Article 17, lets the State override caste exclusion. This has been the aim of the temple entry movement since C. Murugesan's 1925 acquittal at Tiruchanoor, Tirupati [3].
• Definitional disputes: which Article prevails depends on whether a group is a "denomination" and whether a practice is "essential".

How courts have reconciled them

• Harmonious construction: in Sri Venkataramana Devaru, the Madras Temple Entry Authorisation Act prevailed. Article 25(2)(b) controls Article 26(b), though the denomination could keep certain services for its own members [2].
• Narrow reading of "denomination": in Indian Young Lawyers Association (2018, Sabarimala), the majority held that Ayyappa devotees are not a separate denomination. It struck down the exclusion of women by applying constitutional morality [4].
• Unsettled doctrine: in 2019, the interplay of Articles 25 and 26 and the meaning of "sections of Hindus" were referred to a larger Bench. A nine-judge Bench heard the reference in 2026 [5].

Gaps on the ground

• Weak enforcement: Section 3 of the PCR Act, 1955 punishes denial of temple entry on grounds of untouchability. Yet only 24 cases were registered nationwide in 2023, and 965 were pending in courts [6].
• Theology in court: the essential-practices test makes judges rule on doctrine, which denominations see as intrusion into Article 26.

Way forward

• Settle the doctrine through the nine-judge reference. Leave rituals to denominations, but never the question of who may worship.
• Register PCR cases instead of brokering compromises, and fast-track pending trials [6].

The two Articles work together rather than against each other: autonomy governs how worship is conducted, and reform governs who may worship. A century after Murugesan's acquittal [3], a settled doctrine and firm enforcement of Article 17 can carry the Constitution's promise of equality and fraternity to every temple door.