What did the Supreme Court decide in Venkataramana Devaru?

The Court upheld that the Moolky Sri Venkataramana Temple is a public temple open to all Hindus. Article 25(2)(b) applies to public religious institutions, including denominational temples.

How were Articles 25(2)(b) and 26(b) harmonised?

Entry for all Hindus under Article 25(2)(b) is allowed, but denominational management under Article 26(b) remains. Limited exclusions for specific ceremonies were preserved.

Is a denominational temple outside the Act?

No. If the institution is public in character, the Temple Entry law and Article 25(2)(b) apply, even if it was founded for a section of Hindus.

Does the temple fall under Section 2(2) of the 1947 Act?

Yes. It was dedicated for the benefit of a section of the Hindu public (Gowda Saraswath Brahmins), so it is a 'temple' under the Act.

Were special denominational rites protected?

Yes. The Court accepted limited exclusions during specific religious ceremonies, recognising Article 26(b) protection for matters closely tied to worship.

Law Easy

02 November, 2025

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Venkataramana Devaru v. State of Mysore — Temple Entry & Articles 25(2)(b), 26(b) | The Law Easy

VENKATARAMANA DEVARU v. THE STATE OF MYSORE AND ORS.

Temple Entry vs Denominational Rights — balancing Article 25(2)(b) and Article 26(b) with simple, student-first notes.

Supreme Court of India AIR 1958 SC 255 Bench: Supreme Court Temple Entry Act, 1947 Fundamental Rights / Religion ~6 min read

CASE_TITLE: Venkataramana Devaru v. The State of Mysore and Ors. | PRIMARY_KEYWORDS: Temple Entry, Article 25(2)(b), Article 26(b) | SECONDARY_KEYWORDS: denominational temple, Section 2(2) Madras Act 1947, public temple | PUBLISH_DATE: 31 Oct 2025 | AUTHOR_NAME: Gulzar Hashmi | LOCATION: India | Slug: venkataramana-devaru-v-the-state-of-mysore-and-ors

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Quick Summary

The Sri Venkataramana Temple at Moolky was founded for Gowda Saraswath Brahmins. Over time, many Hindus visited it. The State treated it as a public temple under the Madras Temple Entry Authorisation Act, 1947. The trustees said this violated their denominational rights.

The Supreme Court held: the temple is a public religious institution. Article 25(2)(b) allows entry of all Hindus for worship in public institutions, including denominational temples. But Article 26(b) protects management of religious affairs. So, general entry stands, and limited exclusions for certain ceremonies are valid.

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Issues

Can Article 25(2)(b) (temple entry for all Hindus) limit a denomination’s Article 26(b) management rights?
Does the Moolky temple fall within Section 2(2) of the 1947 Act as a “temple,” and is it a denominational temple?

Rules

Article 25(2)(b): The State can make laws opening Hindu religious institutions of a public character to all sections of Hindus.
Article 26(b): Denominations can manage their own affairs in matters of religion, subject to public order, morality, and health.
Harmonisation: Access under Article 25(2)(b) and management under Article 26(b) must be balanced through reasonable limits.

Facts (Timeline)

Founding: Temple established for Gowda Saraswath Brahmin community; managed by community members.

1915: Scheme under CPC Section 92 framed for temple management by the denomination.

1947: Madras Temple Entry Authorisation Act removes entry barriers in public Hindu temples.

1948: Government declares Moolky temple a public temple; Act applies.

1949: Trustees sue, claiming the temple is private/denominational and the Act violates Article 26(b).

Trial Court: Finds the temple used by all classes of Hindus; treats it as a “temple” under Section 2(2).

High Court: Holds it is denominational yet public; Article 25(2)(b) gives all Hindus entry rights.

Supreme Court: Appeal dismissed; public character affirmed; limited denominational rites protected.

Arguments

Appellants (Trustees)

Temple is denominational; management and religious affairs are protected by Article 26(b).
Temple Entry Act should not apply to a denominational institution.
Opening entry dilutes essential denominational practices.

Respondents (State)

Temple has a public character; all Hindus visit and worship there.
Article 25(2)(b) authorises opening public temples to every section of Hindus.
Denominational management can continue alongside general entry.

Judgment (Held)

Appeal and special leave dismissed; High Court view affirmed.
The temple is a public religious institution open to all Hindus under Article 25(2)(b).
Denominational nature recognised; limited exclusions for certain ceremonies are lawful and protected by Article 26(b).
The temple fits Section 2(2) of the 1947 Act since it serves a section of the Hindu public.

Ratio Decidendi

Article 25(2)(b) applies to all public religious institutions, including denominational temples. Entry of all Hindus is permitted. Article 26(b) still protects denominational control over religious affairs. Reasonable, narrow exclusions during specific rituals can coexist with general public access.

Why It Matters

Sets the framework for harmonising open access with denominational autonomy.
Clarifies when a temple is “public” and how Temple Entry laws operate.
Guides future disputes on religious access vs management rights.

Key Takeaways

Public character triggers Article 25(2)(b) entry rights for all Hindus.
Denominational status does not defeat Temple Entry laws.
Article 26(b) safeguards limited religious management and essential rites.
Courts balance access and autonomy through reasonable limits.
Section 2(2) of 1947 Act covers temples for a section of the Hindu public.

Mnemonic + 3-Step Hook

Mnemonic: “OPEN YET OWNED”

OPEN: Public temples are open to all Hindus (Art. 25(2)(b)).
YET: Yet, denominational character is recognised.
OWNED: Own religious management stays for core rituals (Art. 26(b)).

3-Step Hook: Is it public? → Yes, then entry applies. → Preserve core rites under Article 26(b).

IRAC Outline

Issue

Whether public access under Art. 25(2)(b) overrides denominational rights under Art. 26(b) and whether the temple is within Section 2(2) of the 1947 Act.

Rule

Art. 25(2)(b): open access to public temples; Art. 26(b): denominational management of religious affairs; both read harmoniously.

Application

Temple is public in character; entry allowed for all Hindus; limited exclusions during specific rituals preserved.

Conclusion

Appeal dismissed; public access upheld; denominational rites protected in a narrow, defined manner.

Glossary

Denominational Temple: A temple founded for and managed by a specific religious section or denomination.
Public Character: Used and visited by the wider Hindu public, bringing it under laws for open access.
Temple Entry: Policy and laws ensuring all sections of Hindus can enter public temples for worship.

FAQs

Public in character. Though founded for a section, it served the Hindu public; hence Temple Entry law applies.

No. They keep management of religious affairs under Article 26(b), subject to reasonable limits.

Only during specific ceremonies that are intimately tied to denominational practice, and as narrowly tailored by courts.

It defines “temple” under the 1947 Act. If covered, Temple Entry rules apply to that institution.

Reviewed by The Law Easy Fundamental Rights Religious Freedom Administrative Law

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