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Case Snapshot
Citation:- Sastri Yagnapurushadji & Ors. v. Muldas Brudardas Vaishya & Anr., AIR 1966 SC 1119 (Supreme Court of India, decided on 14 January 1966)
- Chief Justice P.B. Gajendragadkar along with Justices K.N. Wanchoo, M. Hidayatullah, V. Ramaswami, and P. Satyanarayana Raju
- Appellants: Sastri Yagnapurushadji and others (followers of the Swaminarayan sect, known as Satsangis).
- Respondent: Muldas Brudardas Vaishya (President of Maha Gujarat Dalit Association)
Legal Backdrop & Issue
Key Legislation:
- Bombay Harijan Temple Entry Act, 1947 and its amendment aimed to permit entry of Harijans (formerly ‘untouchables’) into Hindu temples.
- Bombay Hindu Places of Public Worship (Entry Authorisation) Act, 1956 repealed the earlier Act, reinforcing that all Hindus can enter temples.
Constitutional Provisions:
Articles 17 (abolition of untouchability), 25 (freedom of religion), and 26 (right of religious denominations) were all pivotal to the case.
Could followers of the Swaminarayan sect claim their religious identity was separate from Hinduism and thus exempt from statutory temple-entry laws?
Facts & Case Progression
Trial Court (Ahmedabad, 1951)- Satsangis sought an injunction to block entry of non-Satsangi Harijans into their temples, arguing the legislation did not apply to them. The Trial Court granted this injunction.
- The High Court ruled that the Swaminarayan sect falls within the broader umbrella of Hinduism, and their temples are thus covered by the temple-entry Acts. Consequently, the earlier injunction was overturned.
- The Supreme Court upheld the High Court’s decision, rejecting the claim of a distinct religious identity for the sect and confirming that temple access for Harijans remained valid.
Supreme Court Rationale
- On Procedural Fairness: The Court held that minor procedural mistakes—such as an invalid Vakalatnama (power of attorney submission)—should not doom an entire case. Justice must favor substantive fairness over trivial procedural defects.
- Defining "Hindu": The judgment emphasized that Hinduism is not rigidly defined by creed or uniform practice. Instead, it spans a range of beliefs—respect for the Vedas, devotion to cosmic ideals, pursuit of Moksha (liberation)—and the Swaminarayan sect fits within this broader spectrum.
- Statutory Compliance: Since the Swaminarayan sect is a subset of Hinduism, its temples fall under the purview of the Bombay temple-entry Acts. Therefore, Harijans cannot be denied entry on the basis of untouchability.
Broader Impact
On Religious Identity:This decision affirmed the inclusive nature of Hinduism, where multiple sects—however reformist or distinctive—are recognized under one legal fold.
On Social Equality:
It reinforced the constitutional principle that untouchability-based exclusion from places of worship is impermissible, regardless of internal religious differences.
On Legal Precedent:
The case continues to inform subsequent rulings related to religious freedoms, caste discrimination, and the interpretation of “denomination” under Article 26.
💡 Read Full Case— Sastri Yagnapurushadji & Ors. v. Muldas Brudardas Vaishya & Anr., AIR 1966 SC 1119 (Indian Kanoon).
Summary table of this Case
| Aspect | Summary |
|---|---|
| Citation & Date | AIR 1966 SC 1119; 14 Jan 1966 |
| Main Question | Is the Swaminarayan sect legally Hindu, and do its temples fall under temple-entry Acts? |
| Lower Court Outcomes | Trial Court: Injunction granted; High Court: injunction cancelled |
| Supreme Court Verdict | Swaminarayan sect is within Hinduism; statutory access laws apply |
| Key Significance | Emphasized religious inclusivity, procedural fairness, and anti-discrimination norms |
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