SC to hear review pleas on Sabarimala judgment tomorrow

1. At a Glance

• The Sabarimala temple entry case tests the constitutional balance between individual religious freedom (Article 25) and a religious denomination's right to manage its own affairs (Article 26) — a recurring UPSC theme. [S1]
• A three-judge Bench headed by CJI Surya Kant was scheduled to hear pending review/writ petitions on the 2018 Sabarimala judgment on Monday, February 16, 2026. [S1]
• The matter is entangled with a larger seven-judge Constitution Bench reference covering essential religious practices across faiths (Hindu, Muslim, Parsi, Dawoodi Bohra). [S1]
• Relevant for GS-II (Polity — Fundamental Rights, judicial review) and GS-I (Social — gender justice, religious reform).

2. Why in the News

• The Supreme Court listed the Sabarimala review and writ petitions for hearing on February 16, 2026, before a three-judge Bench led by CJI Surya Kant. [S1]

3. Background & Evolution

• September 28, 2018: A five-judge Constitution Bench (4:1 majority) in Indian Young Lawyers Association v. State of Kerala struck down Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorisation of Entry) Rules, 1965, allowing women of menstruating age (10–50 years) entry into the Sabarimala (Lord Ayyappa) temple in Kerala. [S1]
• Over 60 review and writ petitions were filed challenging the 2018 verdict. [S1]
• November 14, 2019: A five-judge Constitution Bench led by then-CJI Ranjan Gogoi (majority judgment) did not decide the review petitions on merits but referred them to a larger seven-judge Bench, while not expressly staying the 2018 verdict. [S1]
• The 2019 order clubbed the Sabarimala matter with other essentiality-of-religious-practice disputes: entry of Muslim women into mosques, entry of Parsi women married outside the faith into fire temples, and the practice of female genital mutilation (khatna) among the Dawoodi Bohra community. [S1]
• February 16, 2026: A three-judge Bench headed by CJI Surya Kant took up the pending review/writ petitions for hearing. [S1]

4. Core Static Facts

5. Multi-Dimensional Analysis

Legal / Constitutional - Tests the doctrine of "essentiality of religious practice" — whether courts should decide which practices are essential to a religion. - Raises the unresolved tension between Article 25(1) (individual right to practise religion) and Article 26(b) (denominational autonomy), and Article 25(2)(b) (state's social reform power over Hindu institutions). [S1] - The clubbing of unrelated faith practices (mosque entry, Parsi fire temples, FGM) into one reference has been criticised for creating decision-making gridlock.

Social - Directly concerns gender equality and menstrual taboo in religious practice — a core women's-rights issue. - Overlaps with the broader "right to worship vs. custom" debate across multiple religious communities in India.

Ethical / Governance - Illustrates judicial restraint vs. judicial activism debate: the 2019 Bench chose not to enforce/review on merits but to refer upward, delaying finality for over 6 years (2019–2026).

Administrative - Implementation friction between the Kerala government/Devaswom Board and temple traditionalists after the 2018 verdict caused law-and-order issues at Sabarimala (2018-19 protests, not covered in current article but part of known context).

Historical - Continues India's judicial trajectory on temple-entry rights, tracing back to earlier anti-untouchability temple-entry movements (e.g., Vaikom Satyagraha, Temple Entry Proclamation 1936) — a useful comparative link for Mains.

6. Recent Developments (last 12-18 months)

• February 16, 2026: Three-judge Bench headed by CJI Surya Kant scheduled to hear the pending Sabarimala review and writ petitions. [S1]
• (Prior baseline) November 14, 2019: Reference to seven-judge Bench remains pending as of the current hearing — indicating the seven-judge Bench has not yet concluded its consideration.

7. Prelims Hooks

• The original Sabarimala verdict was delivered on September 28, 2018 by a 5-judge Bench with a 4:1 majority. [S1]
• The provision struck down was Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorisation of Entry) Rules, 1965. [S1]
• The case name is Indian Young Lawyers Association v. State of Kerala.
• The dissenting judge in the 2018 verdict was Justice Indu Malhotra.
• The 2019 referral judgment was delivered by a Bench led by then-CJI Ranjan Gogoi, by a 3:2 majority.
• The 2019 judgment referred the matter to a seven-judge Constitution Bench. [S1]
• The 2019 order did not stay the 2018 verdict. [S1]
• Over 60 review/writ petitions challenged the 2018 verdict. [S1]
• The 2019 reference clubbed Sabarimala with: Muslim women's mosque entry, Parsi women's fire-temple entry, and Dawoodi Bohra female genital mutilation practice. [S1]
• Sabarimala temple is dedicated to Lord Ayyappa, located in Kerala.
• The temple is administered by the Travancore Devaswom Board.
• On February 16, 2026, a 3-judge Bench headed by CJI Surya Kant heard the pending petitions. [S1]
• The relevant constitutional articles are Article 25 and Article 26.

8. Mains Relevance

• GS-II: Polity & Governance — "Separation of powers between various organs, dispute redressal mechanisms and institutions"; Fundamental Rights (Articles 25-26); judicial review and pendency of constitutional references.
• GS-I: Indian Society — role of women in society, social empowerment.
• Plausible Mains stems: 1. "Discuss the constitutional tension between individual religious freedom under Article 25 and denominational autonomy under Article 26, with reference to the Sabarimala case." 2. "The referral of the Sabarimala review petitions to a larger Bench has kept the issue in constitutional limbo for over six years. Examine the implications of such delayed adjudication for judicial accountability." 3. "Critically examine the doctrine of 'essentiality of religious practice' as applied by the Supreme Court in matters of gender and religious freedom."

9. Related Topics to Study Next

• Triple Talaq judgment (Shayara Bano case, 2017) — another gender-vs-religion constitutional dispute.
• Right of Muslim women to enter mosques — clubbed with Sabarimala in the same 2019 reference.
• Parsi women's fire-temple entry dispute — clubbed reference case.
• Female genital mutilation among Dawoodi Bohras — clubbed reference case.
• Doctrine of "essential religious practices" — foundational jurisprudential concept underlying all these cases.
• Uniform Civil Code debate — broader personal-law reform context.
• Article 25 & 26 jurisprudence — core constitutional law topic for GS-II.
• Kerala Hindu Places of Public Worship (Authorisation of Entry) Act, 1965 — the parent statute of the struck-down Rule.

10. Common Errors / Trap Areas

• Confusing the 2018 verdict bench (5 judges, 4:1) with the 2019 referral bench (5 judges, 3:2) — different compositions and different outcomes (one decided merits, other only referred).
• Assuming the 2018 judgment was stayed — it was NOT expressly stayed by the 2019 order. [S1]
• Mixing up Travancore Devaswom Board (manages Sabarimala) with generic "Kerala government" as the litigating/managing authority.
• Believing the seven-judge Bench has already ruled — as of the February 2026 hearing, the matter was still before a three-judge Bench handling listing/procedural aspects, indicating the larger reference remains unresolved.
• Conflating this case with the Ayodhya (Ram Janmabhoomi) or Places of Worship Act, 1991 disputes — these are distinct religious-freedom cases, not part of the Sabarimala reference.

11. Sources

• [S1] "SC to hear review pleas on Sabarimala judgment tomorrow", The Hindu — https://www.thehindu.com/todays-paper/2026-02-15/th_international/articleG36FJCH12-13512369.ece — (tier: 4)