Traditional Route To Sabarimala Not An Essential Religious Practice | Kerala High Court Dismisses Plea To Advance Opening Of Traditional Forest Route
Safiya Malik
The High Court of Kerala Division Bench of Justice Raja Vijayaraghavan V and Justice K.V. Jayakumar held that the authorities were justified in opening the Kanana Patha only on the date fixed for the Mandala–Makaravilakku season and declined the request to advance it. The Court noted that the plea sought earlier access to the traditional forest route leading to Sabarimala, but the scheduled opening formed part of a safety- and conservation-oriented regulatory plan governing movement through the Periyar Tiger Reserve. The Bench clarified that postponing the opening does not violate any fundamental right and concluded that the coordinated measures adopted by the responsible departments were appropriate, leaving no ground for interference.
The petitioner, who had secured a virtual queue pass for darshan at Sabarimala on 17 November 2025, approached the Court alleging that authorities had not clearly notified when the traditional forest route from Erumeli to Sannidhanam (Kanana Patha) would open. He stated that indications of the route opening only on 17 November 2025 would prevent pilgrims with passes for that day from undertaking the customary forest trek. He asserted that the path should open by 15 November 2025 and claimed that the absence of timely and transparent communication from the Travancore Devaswom Board and the Forest Department caused hardship to devotees preparing for the journey.
He sought directions preventing the authorities from hindering the pilgrimage through the traditional route and requested publication of advance notifications for the Mandala–Makaravilakku season. He also relied on constitutional provisions relating to equality and religious freedom to argue that restrictions affected his ability to undertake the pilgrimage.
The respondents, including the State, the Travancore Devaswom Board, and the Forest Department, submitted that the route lies within the Periyar Tiger Reserve and is opened only after coordinated consultations under the approved Tiger Conservation Plan. The Forest Department detailed logistical requirements for preparing facilities along the route, stating that they could become functional only by 17 November 2025. The authorities added that all relevant information was disseminated through the “Ayyan” mobile application.
The Court recorded that “the principal prayer of the petitioner is to synchronize the opening of the Kanana Patha with the opening of the temple on 17.11.2025.” It took note of the parties’ consent to hear the matter finally. The Court stated that the issue stood covered by an earlier decision where it was held that restrictions over trekking through the forest route “are essential for ensuring the safety of pilgrims and conservation of the Reserve.”
The Bench noted that the Traditional Route traverses “an ecologically fragile region of significant biodiversity.” It observed that despite only a small fraction of pilgrims taking the forest trek, “serious damage is caused to the Periyar Tiger Reserve” when groups of hundreds move through the terrain. The judgment recorded that pilgrims may stray from designated paths, cook, construct temporary shelters using forest produce, disturb wildlife, and carry plastics. Reference was made to instances where elephants died after ingesting plastic waste and to incidents of human–animal conflict.
The Court stated that the Reserve Forest is “not a transit route” but a living ecosystem the State must conserve. It referred to tragedies in 1999 and 2011 that revealed catastrophic risks of unmanaged pilgrimages. It further observed the need for coordination among District Disaster Management Authorities due to the difficult terrain and unpredictable weather.
On the Virtual Queue system, the Court stated that it was introduced “after the 2011 tragedy” and primarily governs entry through Pamba but influences movement along the forest route as well. The Court recorded that the risks of stampedes, medical emergencies, and human–wildlife encounters justify the restrictions.
The Court stated that safety and preservation of the Reserve demand adherence to carrying capacity, defined as “the maximum number of pilgrims who can be accommodated…without causing unacceptable risks.” Respondents were advised to determine and notify maximum permissible numbers.
On religious rights, the Court observed that Article 25 is subject to public order, morality, and health. It recorded that the mode of reaching the temple is “a means to an end, not the end itself.” It further stated that the traditional route, though customary, is not mandated by scriptures and cannot be treated as an essential religious practice.
The Court held that “there is no reason to interfere with the strict regulatory controls imposed by the competent authorities to ensure the safety of pilgrims, conservation of wildlife, and the ecological integrity of the Periyar Tiger Reserve.”
It recorded that the date for opening the Kanana Patha was fixed “after comprehensive inter-departmental consultation and due diligence” and that the petitioner must “plan and coordinate his travel in accordance with the established schedule.” The Bench stated that the petitioner “cannot insist that the Patha be opened to align solely with his personal convenience.” The writ petition was therefore “dismissed.”
Advocates Representing the Parties
For the Petitioner: Sri. Mathew A. Kuzhalanadan, Shri. Kuriakose Varghese, Smt. SradhaXna Mudrika, Shri. Nabeel B.A., Shri. Cheriyil Sanil John
For the Respondents: Sri. S. Rajmohan, Senior Government Pleader; Sri. G. Biju, Standing Counsel, Travancore Devaswom Board
Case Title: V. Shyamohan v. State of Kerala & Ors.
Neutral Citation: 2025: KER:86782
Case Number: WP(C) 41785 of 2025
Bench: Justice Raja Vijayaraghavan V; Justice K.V. Jayakumar
