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The Madurai Bench of the Madras High Court has declined to direct that Tamil spiritual mantras and hymns must be recited on an equal footing with Sanskrit in the Yaga Salai, Karuvarai and Gopura Vimanam during the Kudamuzhuku of Arulmigu Meenakshi Sundareswarar Temple, Madurai.

The Court also refused to recognise an independent right in favour of a Tamil Velvi Asiriyar, who was not an employee of the temple, to perform Velvi Kundam rituals during the consecration ceremony.

In Tamil Rajendiran @ R. Rajendiran v. Principal Secretary to Government of Tamil Nadu, Justice C. Saravanan held that a Writ Court may implement and declare the law, but cannot create a new ritual entitlement in the absence of legislation or delegated legislation.

Importantly, the Court did not hold that Tamil hymns are prohibited in temples. It recorded that Tamil spiritual mantras and Thirumurai recitation by Othuvars had already been implemented and were being practised. The refusal concerned the further demand for equal ritual participation at specified locations and an individual right to officiate during the Kudamuzhuku.

Case Details

Relief Sought in W.P.(MD) No.11386 of 2026

Tamil Rajendiran @ R. Rajendiran sought a writ of mandamus directing the Tamil Nadu Government and HR&CE authorities to obtain the report of the Expert Committee and permit the use of Tamil spiritual mantras and Tamil hymns along with Sanskrit, on an equal footing, in the Yaga Salai, Karuvarai and Gopura Vimanam.

The prayer covered temple Kudamuzhukkus generally and specifically included the Meenakshi Amman Temple Kudamuzhuku scheduled for 17 September 2026.

The petitioner contended that Tamil devotional mantras and songs were already being used in numerous temple consecrations. He sought the identification and participation of Tamil saints, Othuvars and Velviyalars in Kudamuzhuku ceremonies.

Relief Sought in W.P.(MD) No.12387 of 2026

D. Sureshbabu challenged the order dated 11 March 2026 passed by the Joint Commissioner/Executive Officer of Arulmigu Meenakshi Sundareswarar Temple.

The impugned order rejected his representations dated 17 November 2025 and 24 November 2025 seeking permission for him and his team to perform Tamizh Vazhi Tirukudamuzhuku, including Velvi Kunda Nigalvugal and the chanting of Tamil mantras in Velvi Kundams on par with Sanskrit Yaga Kundams.

Sureshbabu stated that he had undergone religious training, received Asiriyar Tirumuzhaku and performed sacred-fire worship for more than two decades. He argued that allowing Othuvars to sing from a separate place did not give Tamil equal participation in the ritual itself.

Stand of the Meenakshi Temple Administration

The temple administration maintained that the Meenakshi Sundareswarar Temple follows the Kaarana and Kaamiya Agamas in its daily poojas, festivals and Kudamuzhuku.

According to the administration, Sthanika Battars perform the prescribed rituals, while Tamil Othuvars recite Tamil hymns and Thirumurai according to the temple’s established practice.

The authorities referred to the Kudamuzhuku ceremonies conducted in 1923, 1954, 1963, 1974, 1995 and 2009. They stated that Sivachariyars performed Veda Parayanam and 12 Kala Yagasala Poojas, while Othuvars recited the Panniru Thirumurai comprising approximately 17,000 songs, along with Abirami Anthathi, Chokalinga Venba, Sivabogasaram and Meenakshipillai Tamil.

The administration argued that a private individual could not demand, as an enforceable right under Article 226, permission to perform a part of an established Agamic ritual contrary to the temple’s usage and existing arrangements.

Section 28 of the Tamil Nadu HR&CE Act

The temple authorities relied upon Section 28 of the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959. The provision requires a trustee to administer the affairs of a religious institution in accordance with the terms of the trust, the usage of the institution and lawful directions issued by a competent authority.

The expression “usage of the institution” was considered important because the petitioners were seeking an alteration to the persons and procedures involved in the performance of temple rituals.

Constitutional Questions Considered

The High Court treated the dispute as broader than a simple conflict between Tamil and Sanskrit. It examined the relationship between:

• freedom of religion and protection of religious practices under Articles 25 and 26;
• equality and public-employment principles under Articles 14 and 16;
• the exception contained in Article 16(5);
• secular administration of temples and performance of religious rituals;
• the effect of the Agamas governing a particular temple; and
• the limitations of a writ of mandamus under Article 226.

Relevance of Seshammal v. State of Tamil Nadu

The Court extensively considered the Constitution Bench judgment in Seshammal v. State of Tamil Nadu, (1972) 2 SCC 11.

In Seshammal, the Supreme Court upheld the abolition of hereditary succession to the office of Archaka because the act of appointment was secular. However, it recognised that where a temple is governed by a particular Agama, the qualification of the Archaka and performance of worship may still have to conform to the relevant Agamic requirements.

The Madras High Court also referred to Adi Saiva Sivachariyargal Nala Sangam v. Government of Tamil Nadu, (2016) 2 SCC 725, which explained that Articles 25 and 26 must be harmoniously construed with other fundamental rights.

The judgment further noticed N. Adithayan v. Travancore Devaswom Board, where the Supreme Court held that customs violating human dignity, social equality or the constitutional mandate cannot be upheld merely because they existed before the Constitution.

Two Separate Expert Committees

The High Court identified two committees constituted for different purposes:

The distinction was legally significant. Whether a temple must strictly follow a particular Agama depends first upon identifying whether it was constructed according to an Agama and determining the applicable Agama.

The Court also recorded that connected proceedings in Civil Appeal No.7692 of 2023 remained pending before the Supreme Court. The Supreme Court had extended the period for completing the exercise of identifying Agama-governed temples.

Key Findings of the Madras High Court

The operative reasoning is contained in paragraph 120 of the common order. The Court recorded the following important findings:

1. In temples constructed according to Agamas, rituals must be performed strictly in accordance with the applicable Agamas.
2. Whether a particular temple is governed by an Agama must be determined by the committee constituted pursuant to the First Bench order dated 22 August 2022.
3. The recitation of Tamil hymns or hymns in languages other than Sanskrit is being considered by a separate committee constituted pursuant to the order dated 19 August 2021.
4. The committee’s recommendations and the orders passed by the Supreme Court in the pending proceedings will affect the question.
5. The relief sought in W.P.(MD) No.12387 of 2026 could not be granted at that stage because the broader issue was sub judice before the Supreme Court.
6. Unless appropriate rules are framed, a person who is not an employee of the temple cannot independently demand a right to recite hymns or perform the Velvi Kundam component of Kudamuzhuku.
7. The petitioner could participate in the Kudamuzhuku as a devotee.
8. A Writ Court is intended to implement and declare the law; it cannot create a new law or ritual entitlement.
9. Possessing a qualification to chant Tamil hymns does not, by itself, create the specific legal right claimed under Article 226.
10. Denial of an opportunity might possibly offend Article 14, but that issue must be tested through appropriately framed proceedings.
11. Whether wider participation should be permitted in Kudamuzhuku ceremonies is a matter for the Legislature or Executive, subject to constitutional limitations.
12. Tamil spiritual mantras and Tamil hymns by Othuvars had already been implemented and were being practised in temples.

What the Judgment Does Not Decide

The judgment does not ban Tamil hymns at Meenakshi Amman Temple or other Tamil Nadu temples. It does not hold that only Sanskrit may be used in every temple ritual. It also does not prohibit the recitation of Tamil Thirumurai by Othuvars.

The Court refused the specific demand for judicially mandated equal Tamil-Sanskrit recitation in the Yaga Salai, Karuvarai and Gopura Vimanam and the individual petitioner’s request to perform Velvi Kundam rituals.

The judgment also does not finally determine the particular Agama applicable to Meenakshi Sundareswarar Temple. That temple-specific question forms part of the committee exercise referred to in the order.

Possibility of a Future Constitutional Challenge

The Court acknowledged that denial of an opportunity might possibly offend Article 14. However, such a contention would have to be raised through appropriate proceedings challenging a specific rule, resolution, appointment process or exclusionary practice.

Therefore, the judgment should not be understood as granting unlimited protection to every practice described as customary. Any practice alleged to violate equality, dignity or other fundamental rights may still be subjected to constitutional scrutiny in a properly constituted case.

Practical Legal Significance

For HR&CE officials and temple administrators, the judgment highlights the distinction between regulating secular administration and altering religious rituals. Temple records, recognised usage, the applicable Agama, statutory rules and committee findings will be important in future decisions.

For Othuvars and Tamil Velvi Asiriyargal, religious qualification alone may not create an enforceable right to officiate in a particular temple ceremony. A claimant must establish the legal source of the claimed right and challenge the specific procedure that allegedly causes unconstitutional exclusion.

For future litigants, a broadly framed mandamus may fail if it effectively asks the Court to design or modify a religious ceremony. An effective challenge may require identification of the impugned decision, applicable Agama, temple usage, statutory framework and precise violation of Articles 14, 16, 25 or 26.

Final Decision

The Madras High Court dismissed W.P.(MD) No.12387 of 2026 and W.P.(MD) No.11386 of 2026, subject to the detailed observations contained in paragraph 120. No order as to costs was passed.

The immediate legal position is that Tamil hymns already forming part of temple practice may continue. However, the High Court would not compel equal Tamil-Sanskrit recitation at every specified ritual location or confer an independent officiating right upon a non-employee without supporting legislation or rules and before completion of the pending committee and Supreme Court proceedings.

Frequently Asked Questions

Did the Madras High Court ban Tamil hymns at Meenakshi Amman Temple?

No. The Court recorded that Tamil spiritual mantras and hymns by Othuvars were already being practised. It refused only the specific demand for court-ordered equal ritual placement with Sanskrit in the absence of supporting legislation or delegated legislation.

Can a Tamil Velvi Asiriyar claim a right to perform Kudamuzhuku rituals?

Qualification alone is insufficient. The Court held that, unless appropriate rules are framed, a person who is not a temple employee cannot independently demand the right to officiate during the Velvi Kundam component through a writ petition.

Why was Civil Appeal No.7692 of 2023 relevant?

The pending Supreme Court proceeding concerns connected questions involving Agama-governed temples and the committee exercise. The High Court therefore considered the relief sought at this stage to be premature and sub judice.

Can the issue be raised again?

The judgment leaves room for a properly framed challenge before an appropriate forum. A future case must identify a legally enforceable or constitutional right and challenge a specific exclusionary decision or procedure.

Read the full judgment: Tamil Rajendiran @ R. Rajendiran v. Principal Secretary to Government of Tamil Nadu

Disclaimer: This article is a legal-news analysis prepared for general information. It does not constitute legal advice. Readers should refer to the complete judgment and obtain professional advice for specific cases.