Model Answer

The Constitution guarantees both religious freedom and State-led social reform. While Article 26(b) protects the right of religious denominations to manage their own religious affairs, Article 25(2) enables the State to regulate secular activities associated with religion, requiring a constitutional balance.

State control over temple administration

1. Article 25(2)(a) empowers the State to regulate economic, financial, political and other secular activities associated with religious practice. e.g.: Regulation of temple finances and endowments.
2. Article 25(2)(b) authorises the State to enact social welfare and reform measures. e.g.: Temple Entry legislations opening public Hindu temples to all classes and sections.
3. Public religious endowments involve public trust and charitable property, justifying statutory oversight to prevent mismanagement and ensure transparency.

Article 26(b): Constitutional limitation on State control

1. Article 26(b) guarantees every religious denomination the right to manage its own affairs in matters of religion, subject only to public order, morality and health.
2. In Shirur Mutt Case (1954), the Supreme Court held that essential religious practices cannot be subjected to State control, while secular administration may be regulated.
3. Excessive executive control over temple administration may undermine denominational autonomy protected under Article 26.

Constitutional balance

1. The constitutional scheme envisages regulation of secular administration, not management of religious affairs, preserving both accountability and religious liberty.
2. State intervention must satisfy the principles of reasonableness and proportionality, remaining confined to legitimate secular objectives.
3. Independent and transparent statutory mechanisms should replace prolonged executive control wherever feasible.

Articles 25(2) and 26(b) are complementary constitutional provisions. The State may regulate the secular administration of temples in public interest, but it cannot encroach upon the constitutionally protected domain of religious affairs.