Safiya Malik

The Madras High Court, Madurai Bench of Justice B. Pugalendhi directed the reopening of the Arulmigu Mariamman Temple at Chinna Dharapuram, Karur District, to ensure unhindered entry and worship by Scheduled Caste devotees, affirming their constitutional right to equality under Articles 14 and 25. Condemning the District Collector and Superintendent of Police for failing to prevent caste-based exclusion since 2018, the Court ordered that criminal proceedings against those obstructing worship be pursued expeditiously. Emphasising that equality in worship is non-negotiable, the Bench underscored that administrators must uphold fundamental rights and prevent caste discrimination in temple entry.

The petitions before the Madurai Bench of the Madras High Court concerned the dispute over temple entry and worship rights at the Arulmigu Mariamman Temple, Chinna Dharapuram, Aravakurichi Taluk, Karur District. The first writ petition, filed by Vanniyakulachathiriyar Nala Arakattalai, represented by its president Murugan, sought a writ of mandamus under Article 226 of the Constitution. The petitioner requested that the Inspector of Police, Chinnadharapuram Police Station, provide adequate protection to the petitioner, the trustees, and devotees for peaceful worship in the temple, relying on a representation dated 10.07.2024.

Also Read: Supreme Court Orders Uniform Registration of Sikh Marriages | States and UTs Directed to Frame Rules Under Section 6 of the Anand Marriage Act Within Four Months

The second writ petition, filed by Marimuthu, was directed against the order of the Tahsildar, Aravakuruchi Taluk, dated 19.07.2024, which had restricted access to the temple. The petitioner sought issuance of a writ of certiorarified mandamus to quash the impugned order and further direct the authorities, including the District Collector and Superintendent of Police, to reopen the Sri Mariamman Temple for worship by villagers and devotees without discrimination. He also requested that adequate police protection be provided during worship.

Both petitions named multiple state authorities as respondents, including the District Collector, Revenue Divisional Officer, Tahsildar, Superintendent of Police, the Inspector of Police, and officials of the Hindu Religious and Charitable Endowments (HR&CE) Department. In the second petition, the Trust led by Murugan was impleaded as a respondent.

The dispute centered on allegations that members of the Scheduled Caste community were being denied temple entry and worship rights. The petitioners contended that such exclusion violated their fundamental rights to equality and religious freedom guaranteed under the Constitution. Evidence before the Court included prior administrative orders, the closure of the temple since 2018, and reports of obstruction during attempts by Scheduled Caste devotees to enter the premises. The statutory provisions invoked included Article 226 of the Constitution of India for the issuance of writs, as well as references to the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, in connection with caste-based obstruction and the obligations of the police to prevent such offenses.

The Court opened its order by situating the dispute in the historical struggles for temple entry. It recorded: “The struggle for equality in worship has a long and painful history.” Referring to earlier movements, the Court noted: “The Vaikom Satyagraha of 1924–25 in Travancore was the first organised resistance against caste-based restrictions on temple approach roads… The Temple Entry Proclamation of 1936… formally opened all temples in his State to all Hindus irrespective of caste.”

The Court linked this history to Madurai, recording: “The message from Madurai in 1939 was unambiguous, that the walls of caste had no place in the precincts of God.” It then contrasted the past with the present, stating: “Yet, in 2025, this Court is constrained to witness the irony that the very land where Gandhi rejoiced in the breaking of caste barriers in worship, now presents the spectacle of Scheduled Caste devotees being excluded from the Arulmigu Mariamman Temple, Chinna Dharapuram.”

The Court acknowledged compliance with its earlier interim order: “After the order of this Court dated 15.07.2025, it is reported that the members of the Scheduled Caste community were permitted to enter and offer their prayers.” However, it recorded disapproval that such access required judicial intervention: “The fact that such entry has been secured only by an order of this Court is not a matter of pride, but of shame.”

The Court expressed criticism of administrative inaction: “The District Collector, as the chief executive authority of the District, ought to have immediately convened peace meetings between communities… Hiding behind ‘apprehension of disturbance’ for seven long years is nothing but administrative cowardice.” Regarding the Superintendent of Police, it stated: “He should have deployed adequate force during worship, proceeded against caste-based obstructionists under the SC/ST (Prevention of Atrocities) Act, 1989, and maintained law and order by enforcing rights, not by extinguishing them.”

The Court summarized the effect of administrative inaction: “Their inaction is not neutrality; it is betrayal.” It recorded: “The District Collector and the Superintendent of Police of Karur District have displayed an utter abdication of constitutional responsibility… By their conduct, they have confessed that they are unfit to discharge the duties of their office.”

Finally, regarding attempts to block worship, the Court stated: “It is reported that a criminal case in Crime No.74 of 2025 has been registered… against 17 such trouble-mongers… Their conduct is an open defiance of the Constitution and of this Court’s order.”

Justice Pugalendhi directed: "This Court therefore records its strongest condemnation. The State Government is expected to take immediate corrective measures, including replacement of administrators who will uphold constitutional values in letter and spirit."

"This was a moment of justice long delayed, but at last realised. However, this Court notes with dismay that at the very time of such entry, certain persons attempted to obstruct the worship, leading to a commotion." The Court noted the registration of Crime No.74 of 2025 at Chinnadharapuram Police Station against 17 individuals accused of obstruction.

Also Read: Madras High Court | Railway Authorities Cannot Deboard Valid Ticket Holders for Protest Travel | Removal Permitted Only Under Railways Act

"This Court directs that the said criminal case shall be pursued with earnestness and brought to its logical conclusion at the earliest. Only then will a clear message go forth — that those who obstruct constitutional rights will face strict legal consequences, and that equality in worship is non-negotiable. The law must speak firmly, so that no person or group ever again dares to deny temple entry on grounds of caste."

With these directions, the writ petitions were disposed of, with no order as to costs, and connected miscellaneous petitions were closed.

Advocates Representing the Parties

For the Petitioners: Mr. C. Vakeeswaran, Advocate; Mr. S. Gokulraj, Advocate

For the Respondents: Mr. F. Deepak, Special Government Pleader; Mr. E. Antony Sahaya Prabahar, Additional Public Prosecutor; Mr. S. S. Madhavan, Additional Government Pleader; Mr. S. Gokulraj

Case Title: Vanniyakulachathiriyar Nala Arakattalai v. The District Collector, Karur District & Ors. and Marimuthu v. The District Collector, Karur District & Ors.

Case Number: WP(MD)Nos.15950 of 2024, 17212 of 2025

Bench: Justice B. Pugalendhi