Sastri Yagnapurushdasji v Muldas Bhudardas Vaishya (Satsangi case)

Facts

Followers of Swaminarayan (Satsangis) claimed their temples were outside the Bombay Harijan Temple Entry Act 1948, which required every Hindu temple to be open to Harijans (untouchables). They asserted the Swaminarayan sect was a distinct religion unconnected with Hinduism—because Swaminarayan was worshipped as Supreme God, worship of other gods was a betrayal of faith, and there was a separate initiation (diksha). By the time the case reached the Supreme Court, the Central Untouchability (Offences) Act 1955 had also come into force.

Issues

• Whether the Satsangis (Swaminarayan sect) constitute a separate and distinct religion outside Hinduism.
• Whether their temples are 'Hindu temples' subject to temple-entry legislation throwing them open to Harijans.
• What are the distinctive features of the Hindu religion for constitutional purposes.

Arguments

The Satsangis argued that the founder was worshipped as Supreme God, that worship of other deities was forbidden, and that a distinct initiation gave them a separate religious identity outside Hinduism, so the temple-entry Act did not apply. The respondents argued the sect was a reform movement within the broad fold of Hinduism and its temples were Hindu temples subject to the throwing-open mandate of the temple-entry laws.

Held

The Court rejected the claim of separate status, relying on Monier-Williams' account of the sect and the Bombay Gazetteer to conclude the contention was 'entirely misconceived'. Gajendragadkar C.J. then undertook a broad inquiry into the nature of Hinduism, concluding it could not be defined like other religions—it claims no one God, dogma, philosophic concept or set of rites—and 'may broadly be described as a way of life and nothing more'. On this inclusivist view, reform movements and sects (and even Buddhism, Jainism and Sikhism) fall within Hinduism, so the Satsangi temples were Hindu temples bound by the temple-entry Act. The Court could have rested narrowly on Article 25(2)(b), which empowers the State to throw open Hindu institutions to all classes of Hindus, but instead developed its general definition of Hinduism.

Ratio decidendi

Hinduism is an inclusive, amorphous 'way of life' embracing diverse sects and reform movements; a sect that is historically and doctrinally a reform within Hinduism cannot claim to be a separate religion, and its public temples remain subject to Hindu temple-entry legislation.

Significance

The landmark on self-identification and the judicial definition of Hinduism; its 'way of life' construction became hegemonic in later judgments and was used to deny separate-religion status to the Arya Samaj, Ramakrishna Mission, Aurobindo followers and Jains. The same inclusivist reading was controversially carried into the 1995–96 'Hindutva' rulings (Ramesh Yeshwant Prabhoo v Prabhakar Kashinath Kunte) where Hindutva was treated as a 'way of life', a framing appropriated by Hindu nationalist politics.

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