Equal temple entry for all sections of Hindus upheld; Swaminarayan temples remain within the Act.

Section 3 of the Bombay Hindu Places of Public Worship (Entry-Authorisation) Act, 1956 was construed as securing equal entry and worship rights for all sections and classes of Hindus without interfering with a denomination's internal ritual management, so the challenge under Articles 25 and 26 failed. The Swaminarayan sect was treated as remaining within the Hindu fold on the materials regarding its beliefs and practices, and its temples were held to be places of public worship of Hindus or sections of Hindus within the Act. The statutory right of temple entry for non-Satsangi Harijans was therefore upheld.

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Issues: (i) Whether section 3 of the Bombay Hindu Places of Public Worship (Entry-Authorisation) Act, 1956 was ultra vires Articles 25 and 26 of the Constitution of India. (ii) Whether the Swaminarayan sect was a religion distinct and separate from Hindu religion and whether its temples fell within the Act.

Issue (i): Whether section 3 of the Bombay Hindu Places of Public Worship (Entry-Authorisation) Act, 1956 was ultra vires Articles 25 and 26 of the Constitution of India.

Analysis: The provision was construed as securing equal access to Hindu places of public worship for all sections and classes of Hindus, including Harijans, without authorising interference with the internal ritual arrangements of a denomination or section beyond the right of entry and worship in the like manner and to the like extent as other Hindus. The challenge under Article 26(b) failed because the section was held not to invade the denomination's right to manage its own affairs in matters of religion.

Conclusion: Section 3 was held to be valid and not ultra vires Articles 25 and 26.

Issue (ii): Whether the Swaminarayan sect was a religion distinct and separate from Hindu religion and whether its temples fell within the Act.

Analysis: The decision treated Hinduism as a broad and inclusive faith marked by acceptance of the Vedas, plurality of doctrines, diversity of worship, and tolerance of sects and reform movements. On the materials relating to the teachings of Swaminarayan, the initiation practices, and the sect's devotional emphasis, the sect was found to remain within the Hindu fold. Its temples were therefore places of public worship of Hindus or sections of Hindus within the meaning of the Act.

Conclusion: The Swaminarayan sect was held not to be a religion separate from Hindu religion, and its temples were held to fall within the Act.

Final Conclusion: The statutory right of temple entry for all sections and classes of Hindus was upheld, and the appellants' claim to exclude non-Satsangi Harijans from the temples failed.

Ratio Decidendi: A sect that accepts the basic tenets of Hinduism and forms part of the Hindu community cannot exclude other sections of Hindus from a public temple where the statute guarantees equal entry and worship, and a law securing such equality does not infringe the denomination's protected right in matters of religion.

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