Madras High Court Upholds Temple Entry Rights

Context:

On July 17, 2025, the Madras High Court directed state authorities to ensure that Scheduled Caste (SC) devotees are not barred from entering the PuthukudiAyyanar Temple in Tamil Nadu, invoking constitutional and statutory provisions against caste-based discrimination.

Constitutional Provisions Involved:

Article 15(2): Prohibits discrimination on grounds of religion, race, caste, sex, or place of birth in access to public places.
Article 17: Abolishes "untouchability" and forbids its practice in any form.
Article 25(2)(b): Empowers the State to make laws for social welfare and reform, enabling all classes of Hindus to enter and worship in Hindu religious institutions.

Statutory Provision:

Tamil Nadu Temple Entry Authorization Act, 1947:
- Section 3 affirms that any Hindu, regardless of caste or sect, has the right to enter and worship in Hindu temples.
- Overrides any custom, usage, or local law denying access based on caste.
- Provides for legal action against individuals or groups who obstruct such entry.

Judicial Intervention:

The High Court explicitly recognized caste-based denial of temple entry as an “actionable wrong/offence.”
Directed both the Ariyalur Superintendent of Police and Revenue Divisional Officer to enforce the rights of Scheduled Caste worshippers and maintain public order.

Recent Precedent Cases:

Several similar cases in Tamil Nadu, including Dalit temple entry in Tiruvannamalai (2024) after 70 years, indicate a recurring pattern of caste discrimination despite legal safeguards.

Broader Socio-legal Relevance: