Relevance: GS Paper II – Polity and Governance (Fundamental Rights, Supreme Court Judgments, Religious Freedom, Constitutional Morality)

Important Keywords for Prelims and Mains

For Prelims:

  • Sabarimala Temple, Lord Ayyappa, Rule 3(b) Kerala Hindu Places of Public Worship Rules 1965, Indian Young Lawyers Association vs State of Kerala (2018), Articles 14, 25, and 26, Freedom of Religion, Religious Denomination, Essential Religious Practices Doctrine, Supreme Court Review Petition, Constitutional Morality, Gender Equality, Fundamental Rights, Secularism.

For Mains:

  • Sabarimala Temple Entry Case, Indian Young Lawyers Association vs State of Kerala (2018), Essential Religious Practices (ERP) Doctrine, Anti-Exclusion Test, Constitutional Morality, Religious Autonomy vs Fundamental Rights, Justice D.Y. Chandrachud’s Anti-Exclusion Test, Justice Indu Malhotra’s Dissent, Freedom of Religion Jurisprudence, Constitutional Supremacy, Gender Justice, Religious Freedom vs Equality, Articles 14, 25 and 26, Religious Denomination, Secular Constitutional Framework.

Why in News?

  • The Supreme Court of India is set to hear the final arguments in the review petitions related to the Sabarimala Temple entry case (Indian Young Lawyers Association vs State of Kerala, 2018).

    The review will determine the constitutional principles governing the balance between:

    • Religious autonomy
    • Gender equality
    • Individual dignity
    • Constitutional morality

    The outcome will not only affect the Sabarimala dispute but also influence other religious freedom cases involving exclusion and religious practices.

Source : The Hindu

Background of the Sabarimala Case

Traditional Practice

The Sabarimala Temple, dedicated to Lord Ayyappa, traditionally barred women aged 10 to 50 years from entering the temple.

This restriction was based on:

  • The celibate nature of Lord Ayyappa (Naishtika Brahmachari)
  • Long-standing religious customs
  • Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorisation of Entry) Rules, 1965

Supreme Court Judgment (2018)

In September 2018, a five-judge Bench of the Supreme Court of India delivered its verdict.

Majority Judgment (4:1)

The Court ruled that:

  • Devotees of Lord Ayyappa do not constitute a separate religious denomination.
  • The exclusion of women violated their fundamental right to freedom of religion.
  • Rule 3(b) was unconstitutional.
  • Gender discrimination in temple entry violates constitutional guarantees.

The majority emphasized:

  • Equality (Article 14)
  • Freedom of religion (Article 25)
  • Non-discrimination
  • Constitutional supremacy

Dissenting Opinion – Justice Indu Malhotra

Justice Indu Malhotra presented a contrasting view.

Key arguments:

  • Religious practices must be harmonised with constitutional rights.
  • Courts should respect long-standing religious customs.
  • The exclusion of women was an essential religious practice.
  • Courts should not interfere in matters of faith unless there is clear constitutional violation.

Her dissent highlighted the importance of religious autonomy.

Constitutional Framework: Freedom of Religion

  • The Constitution guarantees religious freedom under:

    • Article 25 – Freedom of religion to individuals
    • Article 26 – Rights of religious denominations

    However, these rights are subject to:

    • Public order
    • Morality
    • Health
    • Other fundamental rights such as equality and dignity

    This creates tension between:

    • Religious autonomy
    • Individual fundamental rights

Essential Religious Practices (ERP) Doctrine

Meaning

The Essential Religious Practices (ERP) test allows courts to decide whether a religious practice is essential to a religion.

If essential → Constitution protects it
If not essential → State can regulate or restrict it

Origin of ERP Doctrine

Established in the case:

Sastri Yagnapurushadji vs Muldas Bhudardas Vaishya

The Court interpreted religious texts to determine essential religious practices.

Criticism of ERP Doctrine

The ERP doctrine has several limitations:

  • Courts are forced to interpret religious doctrines.
  • Judges become arbiters of theology.
  • Lack of objective criteria.
  • It does not resolve conflicts between religious practices and human dignity.

It risks allowing exclusionary practices to continue.

Anti-Exclusion Test: A New Constitutional Approach

To overcome the limitations of ERP doctrine, Justice D. Y. Chandrachud proposed the Anti-Exclusion Test.

Meaning of Anti-Exclusion Test

The Anti-Exclusion Test focuses on constitutional impact rather than religious essentiality.

It asks:

  • Does the practice exclude individuals?
  • Does exclusion violate dignity?
  • Does exclusion deny equal access?

If yes → The practice is unconstitutional.

Key Features

  • Religious groups retain autonomy in matters of doctrine.
  • Courts do not decide what is essential to religion.
  • Courts intervene only when exclusion violates constitutional rights.

This shifts focus from: Essentiality of practice → Constitutional impact of practice.

Key Difference: ERP vs Anti-Exclusion Test

Essential Religious Practices TestAnti-Exclusion Test
Focus on religious essentialityFocus on constitutional impact
Courts interpret religious doctrineCourts assess constitutional harm
Protects essential religious practicesProtects dignity and equality
Theological approachConstitutional approach

Broader Constitutional Implications

The principles developed in the Sabarimala case will affect other cases involving religious exclusion, such as:

  • Excommunication practices in Dawoodi Bohra community
  • Rights of Parsi women marrying outside religion
  • Access to religious institutions

These cases raise questions about:

  • Religious autonomy
  • Equality
  • Individual dignity

Religion and Constitutional Morality

The Indian Constitution follows principled secularism.

This means:

  • Religion is protected.
  • But religious practices must comply with constitutional values.

Key constitutional principles include:

  • Equality
  • Liberty
  • Dignity
  • Non-discrimination

The Constitution prioritizes individual dignity over discriminatory customs.

Constitutional Balance: Faith vs Fundamental Rights

The Constitution recognizes both:

  • Rights of religious communities
  • Rights of individuals

However, when religious practices violate dignity or equality, constitutional values prevail.

The individual remains the basic unit of constitutional protection.

Significance of the Sabarimala Review

The review will decide:
  • Scope of religious freedom
  • Limits of religious autonomy
  • Role of courts in religious matters
  • Balance between faith and fundamental rights
The judgment will shape India’s religious freedom jurisprudence for decades.

Conclusion

The Sabarimala case represents a major constitutional debate between religious freedom and individual rights.

The essential religious practices doctrine has faced criticism for allowing courts to interpret theology. The anti-exclusion test offers a more constitutional approach by focusing on dignity and equality.

The Supreme Court’s final ruling will define how India balances religious autonomy with constitutional morality, ensuring that faith remains protected while preventing discrimination.

CARE MCQ

Q. ‘Mission Indradhanush’ launched by the Government of India pertains to (2016)

  1. The Supreme Court held that devotees of Lord Ayyappa constitute a separate religious denomination.
  2. The Essential Religious Practices doctrine allows courts to determine essential religious practices.
  3. The Anti-Exclusion Test focuses on dignity and equality rather than religious essentiality.

Which of the above statements is/are correct?

A.  1 and 2 only
B.  2 and 3 only
C.  1 and 3 only
D.  1, 2 and 3

Answer: B

Explanation

Statement 1 is Incorrect
The Court held that Ayyappa devotees are not a separate religious denomination.

Statement 2 is Correct
ERP doctrine allows courts to determine essential religious practices.

Statement 3 is Correct
Anti-Exclusion Test focuses on dignity and equality.

Relevance: GS Paper II – International Relations

Important Keywords for Prelims and Mains

For Prelims:

  • Mark Carney Visit (2026), Nijjar Assassination Allegations (2023), Diplomatic Expulsion & Withdrawal of High Commissioners, Comprehensive Economic Partnership Agreement (CEPA), G7 Summit Outreach (2025), Five Eyes Alliance, Joint Working Group on Counter-Terrorism (1997),

For Mains:

  • Diplomatic Reset & Strategic Stabilisation, Law Enforcement vs Political Dispute Approach, Institutional Firewalls in Bilateral Relations, Diaspora Politics & Khalistan Issue, Transnational Crime Mechanism (NSA Framework), Trade Diversification Strategy, Energy Security & Critical Minerals Partnership, Education Diplomacy & Student Mobility (3.92 lakh students), Geopolitical Convergence (G7–Five Eyes–G20), India–Canada–Australia Trilateral Technology Partnership

Why in News?

Canadian Prime Minister Mark Carney’s visit to India in February–March 2026 marks a major turning point in India–Canada relations. His arrival signals efforts by both countries to restore diplomatic, economic, and strategic engagement after a serious diplomatic crisis that strained bilateral ties since 2023.

Carney’s visit includes meetings with Prime Minister Narendra Modi in Mumbai and New Delhi, reflecting renewed high-level political dialogue and cooperation.

Background: Diplomatic Crisis in 2023

India–Canada relations deteriorated sharply in September 2023 following allegations made by then Canadian Prime Minister Justin Trudeau.

The Nijjar Assassination Allegations

  • Justin Trudeau alleged in the Canadian Parliament that Indian government agents may have been involved in the killing of Khalistani separatist Hardeep Nijjar in British Columbia in June 2023.
  • Trudeau also raised the issue with Prime Minister Narendra Modi during the G20 Summit.

India strongly rejected the allegations and described them as “absurd and motivated.”

Diplomatic Escalation and Consequences

The allegations triggered a major diplomatic confrontation between the two countries.

Key developments included:

  • Expulsion of diplomats by both countries
  • Withdrawal of High Commissioners
  • Closure of consulates and reduction in diplomatic engagement
  • Suspension and restrictions in visa services

These measures are usually seen in situations of war or severe diplomatic breakdown.

India also accused Canada of providing a safe haven to extremists and separatist groups.

Impact of Diplomatic Crisis

The diplomatic crisis affected multiple dimensions of bilateral relations.

Political Impact

  • Breakdown of diplomatic dialogue
  • Suspension of high-level visits

Economic Impact

  • Slowdown in economic cooperation
  • Uncertainty in trade negotiations

People-to-People Impact

  • Visa restrictions affected students and migrants
  • Educational and cultural exchanges were disrupted

Diplomatic Recovery Under Prime Minister Mark Carney

  • The process of normalization began after political leadership changes in Canada.

    Leadership Transition

    • Justin Trudeau stepped down in January 2025
    • Mark Carney became Prime Minister in March 2025
    • His government adopted a pragmatic approach to restore relations

    Carney treated the Nijjar case as a law enforcement issue rather than a political dispute, enabling diplomatic engagement to resume.

Diplomatic Initiatives to Restore Relations

  • Several diplomatic steps were taken to rebuild trust and cooperation.

    High-Level Political Engagement

    • Carney invited Prime Minister Modi to the G7 Summit outreach meeting in Canada in June 2025.
    • The meeting was described as positive and constructive.

    Both leaders agreed to take steps to restore stability in bilateral relations.

Restoration of Diplomatic Representation

  • Key diplomatic normalization measures included:

    • Return of High Commissioners to respective capitals
    • Reinstatement of diplomats
    • Removal of visa restrictions
    • Resumption of diplomatic and security dialogue

Creation of New Security Dialogue Mechanism

  • To prevent security issues from affecting broader relations, both countries established a new framework under their National Security Advisors.

    This framework focuses on addressing:

    • Transnational crimes
    • Extremism-related concerns
    • Security cooperation

    This mechanism allows security issues to be handled separately from economic and diplomatic relations.

Trade and Economic Cooperation

  • Economic relations remain one of the strongest pillars of bilateral engagement.

    Trade Volume and Economic Partnership

    • Bilateral trade reached $30.8 billion in 2024.
    • India is Canada’s seventh-largest trading partner.

    Both countries have launched negotiations for a Comprehensive Economic Partnership Agreement (CEPA) to increase bilateral trade to $70 billion by 2030.

Major Exports and Imports

India’s exports to Canada include:

  • Pharmaceutical products
  • Machinery and mechanical appliances
  • Electronic goods
  • Iron and steel
  • Organic chemicals
  • Gems and jewellery
  • Textile products

Canada’s exports to India include:

  • Pulses
  • Fertilizers such as potash
  • Minerals and natural resources

Investment Relations

Canada is an important investor in India.

  • Canada is the 17th largest foreign investor in India.
  • Canadian investment in India totals $4.18 billion between 2000 and 2025.

Investment sectors include:

  • Infrastructure
  • Renewable energy
  • Technology
  • Financial services

Security and Defence Cooperation

India and Canada cooperate on global security issues through institutional frameworks.

Key Security Cooperation Mechanisms

  • Joint Working Group on Counter-Terrorism (established 1997)
  • Countering Terrorism and Violent Extremism Framework (2018)

Regular meetings between National Security Advisors help strengthen security coordination.

Energy Cooperation

Education is a key pillar of people-to-people relations.

  • Over 3.92 lakh Indian students were studying in Canada as of December 2024.
  • Indian students form the largest international student group in Canada.

Educational cooperation includes:

  • Academic exchange programmes
  • Joint research collaborations
  • Institutional partnerships

Role of Indian Diaspora in Canada

Canada has one of the largest Indian diaspora populations in the world.

  • Over 1.8 million Canadians are of Indian origin
  • Around 1 million Non-Resident Indians live in Canada

The diaspora contributes to:

  • Economic growth
  • Cultural exchange
  • Strengthening bilateral relations

However, a small minority of pro-Khalistan groups influenced political tensions in recent years.

Geopolitical Significance of Canada for India

Canada is an important global strategic partner.

Canada is a member of:

  • G7 group of major economies
  • Five Eyes intelligence alliance

Both groups include key strategic partners of India such as:

  • USA
  • UK
  • Australia
  • Japan

India, Canada, and Australia have also launched a trilateral technology partnership to strengthen cooperation in:

  • Critical technologies
  • Supply chain resilience
  • Innovation

Strategic Importance of Diplomatic Reset

The normalization of India–Canada relations is important for several reasons.

Economic Importance

  • Expands trade and investment opportunities
  • Supports economic growth

Strategic Importance

  • Strengthens geopolitical cooperation
  • Enhances security coordination

Technological Importance

  • Supports innovation and technology collaboration

Educational and Cultural Importance

  • Strengthens people-to-people relations

Conclusion

India–Canada relations experienced a serious diplomatic crisis in 2023 due to political allegations and diplomatic tensions. However, leadership changes in Canada and sustained diplomatic engagement helped restore bilateral cooperation. Prime Minister Mark Carney’s visit to India marks an important step in rebuilding trust and strengthening political, economic, and strategic relations. Both countries recognize the importance of their partnership in addressing global economic, technological, and geopolitical challenges, and the restoration of relations is expected to strengthen long-term cooperation.

UPSC PYQ

Q. Consider the following statements with regard to the G7:

  1. The G7 is a formal grouping of leading industrialised nations.
  2. The European Union has been part of all working sessions of the G7 since the 1981 Ottawa Summit.
  3. The Group of Eight was constituted in 1998 as Russia became a member of the grouping.

How many of the statements given above are correct?

A. Only one

B. Only two

C. All three

D. None

Answer: B

CARE MCQ

Q. In which one of the following groups are all the countries members of the G7 Summit?

A. Canada, France, Germany and Italy

B. India, Japan, United Kingdom and United States

C. China, France, Germany and Japan

D. Russia, Italy, United Kingdom and United States

Answer: A

Explanation

The G7 countries are:

  • Canada
  • France
  • Germany
  • Italy
  • Japan
  • United Kingdom
  • United States

These are the seven major developed economies that form the G7 group.

UPSC Daily Current Affairs 26th February 2026
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