Introduction:

The Madras High Court, in Madhavan Ramanuja Dasan v. The Commissioner, HR & CE, 2026 LiveLaw (Mad) 396, has reiterated the principle that all living beings are equal before God and that religious worship should not be governed by discriminatory treatment. A Division Bench comprising Justice G. Jayachandran and Justice E. Manoharan made the observation while considering a petition alleging discriminatory treatment of non-Brahmin devotees at the Arulmigu Devaraja Swamigal Temple at Kancheepuram, particularly at the Sri Manavala Mamunigal Shrine.

At the outset of its consideration, the Court referred to Chapter 9, Verse 29 of the Bhagavad Gita, quoting the teaching attributed to Lord Krishna that He is equally disposed towards all living beings and neither favours nor hates anyone. Drawing from this spiritual principle, the Bench observed that, in the eyes of God, all living beings are equal and God does not discriminate. The observation formed an important backdrop to the Court’s consideration of the allegations concerning access to temple spaces, religious recitation and distribution of sacred offerings.

The petitioner, Madhavan Ramanuja Dasan, claimed to be a devotee of Lord Devarajaswamy at Kancheepuram. He approached the High Court alleging that non-Brahmin devotees were being subjected to discriminatory treatment at the temple. His principal grievance concerned the Sri Manavala Mamunigal Shrine, where, according to him, there were two entrances, namely a main entrance and a side entrance. The petitioner alleged that non-Brahmin devotees were not permitted to use the main entrance while other devotees were permitted to do so.

According to the petitioner, such a practice amounted to discrimination on the basis of caste and was inconsistent with the principle that devotees should be treated equally within a public temple. He also alleged that non-Brahmin devotees were prevented from reciting hymns in various shrines within the Devarajaswamy Temple. His allegations extended beyond physical access and included the manner in which religious privileges and sacred offerings were allegedly distributed.

The petitioner specifically raised concerns regarding the distribution of prasadam, theertham and satari. He alleged that differential treatment was being accorded to devotees in these matters and that such treatment created an unequal religious environment within the temple. His case was that the administration had a duty to ensure that devotees were treated equally and that caste-based distinctions could not be sustained under the guise of temple practice or tradition.

The petitioner also relied upon an earlier communication issued by the Assistant Commissioner of the Hindu Religious and Charitable Endowments Department. According to the petitioner, the Assistant Commissioner had expressly stated that there should be no discrimination and that strict action would be taken if discriminatory practices were found to exist. Despite this assurance, the petitioner claimed that the alleged discriminatory practices continued, compelling him to invoke the jurisdiction of the High Court.

The matter therefore raised questions concerning the relationship between temple traditions, religious practices, administrative arrangements and the principle of equality. The Court was required to consider whether the practices complained of genuinely amounted to discriminatory treatment or whether they could be explained by the physical structure of the shrine, established religious traditions or statutory rights attached to particular forms of temple service.

The Executive Trustee of the temple disputed the allegations. The temple administration maintained that there was no intention to discriminate against non-Brahmin devotees. With regard to access to the shrine, it was submitted that the sub-shrines were relatively small structures and that it was practically impossible to permit the entire body of devotees to enter them simultaneously.

The administration also gave an assurance before the Court that no member of the public would be discriminated against in the distribution of theertham, prasadam and satari. The assurance was significant because these offerings form an important part of temple worship and religious observance, and unequal distribution on the basis of caste could raise serious constitutional and administrative concerns.

With regard to the recital of hymns, particularly the Nalayira Divya Prabandham, the respondents explained that a particular right existed in favour of persons holding the Adhyabaga Mirasi associated with the Thengalai sect. According to the temple administration, this was not simply a privilege based on caste but a statutory or customary right carrying with it remuneration and preferential rights of honours.

At the same time, the administration clarified that apart from the specific statutory or traditional right attached to the Adhyabaga Mirasi, the temple authorities did not prevent the petitioner or any other devotee from reciting the Nalayira Divya Prabandham in any shrine when they came to worship.

After considering the submissions, the High Court concluded that if the position explained by the temple administration was preserved in practice, following the relevant tradition would not necessarily result in discrimination. The Court therefore closed the petition while taking note of the assurances and explanations placed before it.

The decision is noteworthy because it does not merely concern the physical management of a temple. It engages with the broader question of equal treatment in religious spaces while also recognising that temples may have established practices and legally protected rights associated with particular forms of worship or service. The Court’s approach demonstrates the need to distinguish between a genuine discriminatory practice and a religious or administrative arrangement that, when properly implemented, does not deny equal access or participation to members of the public.

Arguments of the Parties:

The petitioner, Madhavan Ramanuja Dasan, approached the Madras High Court alleging that discriminatory practices were being followed at the Arulmigu Devaraja Swamigal Temple in Kancheepuram. His principal complaint was that non-Brahmin devotees were allegedly treated differently from other devotees in relation to access to the Sri Manavala Mamunigal Shrine.

The petitioner submitted that the shrine had two entrances, one being the main entrance and the other a side entrance. According to him, non-Brahmin devotees were not permitted to enter through the main entrance and were instead required to use the side entrance. He argued that such differential treatment had no legitimate basis and amounted to discrimination on the ground of caste.

The grievance was not confined to the entrance arrangement. The petitioner also alleged that non-Brahmin devotees were prevented from reciting hymns in various shrines of the temple. He contended that the Nalayira Divya Prabandham, being an important body of devotional Tamil literature associated with Sri Vaishnavism, should not be subject to discriminatory restrictions preventing ordinary devotees from participating in its recital.

The petitioner further complained about the distribution of prasadam, theertham and satari. These are important components of temple worship, and the petitioner alleged that devotees were not treated equally when these sacred items were distributed. According to his case, any distinction based upon caste would be incompatible with the principle of equality that should govern access to a public religious institution.

The petitioner relied upon the communication issued by the Assistant Commissioner of the Hindu Religious and Charitable Endowments Department. He submitted that the Department itself had acknowledged the importance of preventing discrimination and had warned that strict action would be taken if discriminatory practices were found. According to the petitioner, the continued existence of the alleged practices despite that communication demonstrated that administrative intervention had been ineffective.

The petitioner therefore sought the intervention of the High Court to ensure that the temple administration did not discriminate between devotees on the basis of caste. His case was founded upon the broader proposition that religious worship in a public temple should be accessible to devotees without arbitrary distinctions and that traditional practices could not be used as a justification for discriminatory treatment.

The respondents, represented by the temple administration and the Hindu Religious and Charitable Endowments Department, disputed the allegations. The Executive Trustee submitted that the allegations of discrimination did not accurately reflect the manner in which the temple was being administered.

With respect to the alleged restriction concerning the main entrance to the Sri Manavala Mamunigal Shrine, the administration explained that the relevant sub-shrines were small structures. It was therefore practically impossible to permit the entire public to enter the shrine at the same time. According to the respondents, any regulation concerning entry was attributable to the physical limitations of the shrine rather than an intention to discriminate against a particular class of devotees.

The respondents also gave a clear assurance concerning the distribution of theertham, prasadam and satari. They informed the Court that the temple would not discriminate against any portion of the public in this regard and that all members of the public would be treated equally.

This assurance addressed one of the petitioner’s central concerns. If sacred offerings are distributed without caste-based distinction, the mere existence of an administrative arrangement concerning movement within a small shrine would not necessarily amount to discrimination.

The respondents gave a separate explanation concerning the recital of hymns. They informed the Court that the right to recite the relevant hymns in the particular context was connected with the Adhyabaga Mirasi associated with the Thengalai sect. According to the administration, the right was statutory and carried corresponding remuneration as well as a preferential right to honours.

The respondents therefore sought to distinguish a specific legally or traditionally recognised right from a general prohibition against ordinary devotees participating in religious recitation. They clarified that, except insofar as the special right of the Adhyabaga Mirasi was concerned, the temple administration did not prevent the petitioner or any other devotee from reciting the Nalayira Divya Prabandham in any of the temple’s shrines.

The respondents’ position was consequently that there was no blanket prohibition against non-Brahmins participating in worship or recitation. The particular rights associated with the Adhyabaga Mirasi were based on a recognised tradition or statutory arrangement and should not automatically be characterised as caste discrimination.

The respondents also emphasised the importance of preserving established temple traditions. Their case was not that a devotee should be treated differently because of caste, but that certain traditional rights and methods of worship have historically been associated with specific religious roles. Such arrangements, they contended, could coexist with equal treatment of the general public provided that the general right of worship was not denied.

The rival submissions thus presented the Court with two competing understandings of the practices in question. The petitioner viewed the differential arrangements as evidence of caste-based exclusion, while the temple administration characterised them as consequences of physical limitations, established religious rights and traditional practices that did not prevent ordinary devotees from worshipping or participating in recitation.

The High Court was therefore required to determine whether the practices, as explained by the respondents, actually resulted in discrimination or whether they could be maintained without denying equality to devotees.

Court’s Judgment:

The Madras High Court, comprising Justice G. Jayachandran and Justice E. Manoharan, considered the allegations and the explanations placed before it by the temple administration. Before proceeding with the substantive consideration, the Bench referred to the Bhagavad Gita, specifically Chapter 9, Verse 29.

The Court quoted the teaching that God is equally disposed towards all living beings and neither favours nor hates anyone. Drawing from this principle, the Bench observed that, in the eyes of God, all living beings are equal and God does not discriminate.

The reference to the Bhagavad Gita provided a philosophical foundation for the Court’s consideration of the petition. It underscored the idea that religious institutions should not become instruments for arbitrary discrimination among devotees. At the same time, the Court did not conclude that every difference in religious practice or temple administration automatically constitutes unlawful discrimination.

The Court carefully considered the explanation offered by the Executive Trustee regarding the physical structure of the shrine. The administration had submitted that the sub-shrines were small and that permitting the entire public to enter them simultaneously was practically impossible.

The Court took note of this explanation. A restriction arising solely from the physical capacity of a shrine is fundamentally different from a restriction imposed on the basis of caste. If the same practical limitation applies equally to devotees and is administered without discriminatory preference, the arrangement does not necessarily violate the principle of equality.

This distinction was central to the Court’s approach. The existence of separate entrances or regulated movement within a small religious structure cannot, without further evidence, establish caste discrimination. The Court was concerned with whether the practical arrangement resulted in unequal treatment rather than simply whether different routes or procedures existed.

The Court also took note of the assurance given by the temple administration concerning the distribution of theertham, prasadam and satari. The administration expressly stated that it would not discriminate against any section of the public in this regard and that all devotees would be treated equally.

This assurance was important because the distribution of sacred offerings is an integral part of temple worship. If such offerings were distributed according to caste, the practice could raise a serious question of discriminatory treatment. By assuring the Court that no such distinction would be made, the temple administration addressed a significant portion of the petitioner’s grievance.

The Court’s reasoning demonstrates that assurances made by public authorities and temple administrators can have legal significance when they directly address the alleged discriminatory practice. The Court was satisfied that, if the assurance was preserved and implemented, there would be no discrimination in the distribution of theertham, prasadam and satari.

The issue concerning the recital of hymns required a somewhat different consideration. The temple administration informed the Court that the right to recite the hymns in the relevant context was connected to the Adhyabaga Mirasi of the Thengalai sect. It was submitted that this right was statutory and carried with it a right to remuneration and a preferential right of honours.

The Court took note of this explanation and distinguished such a specific right from an absolute prohibition against other devotees reciting the Nalayira Divya Prabandham. The administration clarified that, apart from the special right attached to the Adhyabaga Mirasi, it did not prevent the petitioner or any other person from reciting the hymns in the temple’s shrines when they wished to worship.

This distinction enabled the Court to reconcile the preservation of a recognised traditional or statutory right with the broader principle of equal access to worship. The existence of a preferential right for a particular religious function does not necessarily mean that all other devotees are prohibited from engaging in devotional recitation.

The Court’s approach is therefore one of accommodation rather than automatic invalidation of tradition. A temple may preserve a recognised religious practice or traditional entitlement, provided that such practice does not result in discriminatory exclusion of the public from worship or the benefits of religious observance.

The judgment is particularly significant because it places equality at the centre of the discussion without treating equality as necessarily requiring the elimination of every distinction in temple practice. The legal question is whether the distinction has the effect of denying equal treatment or access to devotees because of their caste or other impermissible grounds.

The Court’s reliance on the Bhagavad Gita also reflects the cultural and religious context in which the dispute arose. The reference was not used to replace legal standards with religious doctrine. Rather, it served to reinforce the broader moral principle that the divine does not discriminate among living beings.

The Court therefore proceeded on the basis that the administration must ensure equal treatment while also examining whether the specific practices complained of were genuinely discriminatory. Where a restriction is imposed because a shrine is physically small, rather than because a devotee belongs to a particular caste, the restriction cannot automatically be characterised as discrimination.

Similarly, where a traditional right of recitation or honour is legally recognised, its preservation does not necessarily violate equality if ordinary devotees remain free to participate in worship and recite the hymns.

The Court’s approach also reflects the importance of examining the actual effect of a temple practice rather than relying solely upon its description. A practice described as “traditional” cannot automatically be protected if it results in prohibited discrimination. Conversely, a practice should not be struck down merely because different religious functions or rights are distributed according to established traditions when those traditions do not prevent other devotees from worshipping equally.

The Court ultimately accepted the submissions made by the temple administration and found that, so long as the stated position was preserved, following the relevant tradition would not result in discrimination. The administration’s assurance regarding equal distribution of theertham, prasadam and satari, together with its clarification concerning the recital of hymns, addressed the principal concerns raised by the petitioner.

The Court therefore did not issue a direction requiring the temple to abandon its traditional arrangements. Instead, it took note of the assurances and closed the writ petition.

The decision should not be understood as permitting caste discrimination in temples. Quite the contrary, the Court’s opening observation expressly emphasised equality before God. The judgment makes clear that members of the public must not be subjected to discriminatory treatment in matters of temple worship merely because of their caste.

What the Court recognised was that not every distinction amounts to discrimination. Physical limitations of a shrine can necessitate regulated entry, and legally recognised traditional rights may coexist with equal access to worship. The critical requirement is that such arrangements should not be implemented in a manner that excludes or humiliates devotees on te basis of caste.

The case also illustrates the import