Temple Festivals Conducted by State Cannot Perpetuate Caste Names

Source: Madras High Court 

Why in News? 

Justice Bharata Chakravarthy of the Madras High Court, in the case of N Samaran v. The Commissioner and Others (2026), observed that temple festivals conducted by the State through the Hindu Religious and Charitable Endowment (HR&CE) Department cannot be permitted to perpetuate caste by prominently advertising caste names in festival invitations. 

What was the Background of N Samaran v. The Commissioner and Others (2026) Case? 

• The petition was filed by N Samaran seeking directions to the Commissioner HR&CE, the Joint Commissioner of HR&CE, and the Executive Officer of the Arulmigu Kandhasamy Thirukovil to prohibit the use of caste names in the invitation for the upcoming temple festival. 
• The petitioner additionally sought a direction permitting only persons authorised by the Executive Officer to participate as "Sri Padhamthangis" to carry the idol during the procession. 
• When the matter was taken up, the State informed the court that the temple itself was not using any caste name, but acknowledged that caste names of persons had been printed in the festival invitation. 
• The State submitted that since invitations had already been printed, no further directions could be issued for the present festival year. 

What were the Court's Observations? 

• The court observed that caste exists only in the minds of people and that the concept of caste is based solely on birth, which alone divides people. 
• Justice Chakravarthy emphasized that Article 14 of the Constitution of India enshrines the principle of equality and that the very purpose of India becoming a Republic was to treat everyone equally. 
• The court categorically held that if a festival in which a Government Department, namely the HR&CE Department, is involved is conducted so as to propagate caste and advertise or take pride in one's caste, the same cannot be permitted. 
• The court directed that from the ensuing festival onwards, if any person adds their caste name along with their name, the caste suffix alone shall be dropped and only the name shall be printed in the invitation. 
• The court rejected the State's prayer to leave the matter open to the temple and issued the aforesaid direction. 
• With respect to the prayer regarding appointment of persons for the procession, the court noted that volunteers usually carry the idol and it is typically managed on the spot by able-bodied devotees. 
• The court declined to frame any Standard Operating Procedure (SOP) for temple processions, observing that such micromanagement would open a Pandora's box and should be left to the persons managing the temple on the ground. 

What is Article 14 of the COI? 

About:  

• Article 14 of the Constitution of India, 1950 affirms the fundamental right of “equality before the law” and “equal protection of law” to all persons. 
• The first expression “equality before law” is of England origin and the second expression “equal protection of law” has been taken from the American Constitution. 
• Equality is a cardinal principle enshrined in the Preamble of the Constitution of India as its primary objective. 
• It is a system of treating all human beings with fairness and impartiality. 
• It also establishes a system of non-discrimination based on grounds mentioned in Article 15 of the Constitution of India. 

Concept:  

• The guarantee of equality before the law is an aspect of what Dicey calls the Rule of Law. 
• It was held in the matter of Rubinder Singh v. Union of India (1983) that, the rule of law requires that no person shall be subjected to harsh, uncivilized or discriminatory treatment even when the object is the securing of the paramount exigencies of law and order. 
• The purpose of Article 14 is to give similar treatment to similarly circumstanced persons, both in privileges conferred and liabilities imposed. 
• Classification must not be arbitrary but must be rational. 
• It was held in the matter of Indira Nehru Gandhi v. Raj Narain (1975) that, the Rule of Law embodied in Article 14 is the basic feature of the Indian Constitution and hence it cannot be destroyed even by an amendment of the Constitution under Article 368 of the Constitution of India. 
• The protection of Article 14 extends to citizens and non-citizens both. 

Definitions 

• Article 14: Equality before law - “The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India.” 
• Dr. Jennings - “Equality before the law means that among equals the law should be equal and should be equally administered, that like should be treated alike.” 
• Chief Justice Pantanjali Shastri - “The second expression is corollary of the first and it is difficult to imagine a situation in which the violation of the equal protection of laws will not be the violation of the equality before law. Thus, in substance the two expressions mean one and the same thing.” 

Exceptions: 

• Article 361A provides special privileges to the Members of Parliament (MP) and Members of State Legislative Assembly (MLA) to not be present before any court during the session. 
• Articles 105 and 194 prevent the MLAs and MPs from being answerable before the court for their speeches and opinions. 
• President and Governors are privileged for not being answerable to any court with respect to the functioning of their duties and powers under Article 361. 
• The abovementioned authorities are immune from any arrest during their term under Article 361. 
• Any criminal case cannot be instituted against President and Governors of states. 
• Any civil proceeding against President and Governors can only be initiated after a prior notice of 2 months. 
• Article 31C is an exception to Article 14. It provides that the law made by the state for implementing the Directive Principles contained in clause (b) or clause (c) of Article 39 cannot be challenged on the ground that they are violative of Article 14. In the case of Sanjeev Coke Mfg. Co v. Bharat Cooking Coal Ltd. (1982), it was held that, “where Article 31C comes in Article 14 goes out”. 
• The foreign sovereigns (rulers), ambassadors and diplomats enjoy immunity from criminal and civil proceedings. 
• The United Nations Organization and its agencies enjoy the diplomat’s immunity. 

Test for Reasonable Classification: 

• Article 14 forbids class legislation however, it does not forbid reasonable classification of persons, objects and transactions by the legislature for the purpose of achieving specific ends. 
• Two conditions were demarcated in the case of State of West Bengal v. Anwar Ali Sarkar (1952) 
• There must be a presence of intelligible differentia, where application of law must not be universal upon each human. 
• The differentia applied must align with the cardinal objective of the state. 

Doctrine of Arbitrariness:  

• Fairness and Arbitrariness are antithetical to each other, both concepts cannot be present in a single box. 
• Hence, the court of law attempted to bring an evolution in the list of reasonable classification by excluding the decision containing arbitrariness. 
• This doctrine was coined in the case of E.P Rayappa v. State of Tamil Nadu (1973), where the bench termed equality as a dynamic concept and the ambit of reasonable classification cannot be altered by the usage of arbitrariness. 
• The doctrine was later applied to the cases of Maneka Gandhi v. Union of India (1978) and R.D. Shetty v. International Airport Authority (1979) into which courts opined that arbitrariness refers to deprivation of equality.