Court holds that practice of endogamy is not an essential religious practice; denies Church authority to excommunicate members marrying outside community, affirming constitutional rights under Article 25.
In a landmark judgment delivered on 23rd March 2026, the Kerala High Court decisively ruled that the practice of endogamy among the Knanaya Catholic Community is neither an essential religious practice nor legally enforceable to the extent of denying church membership or sacraments. The case, titled The Metropolitan Archbishop v. Knanaya Catholic Naveekarana Samithy, involved a legal challenge to the Kottayam Diocese’s policy of terminating membership of individuals who married Catholics from outside the Diocese, effectively enforcing endogamy.
The Court meticulously analyzed the historical, canonical, and constitutional aspects of the practice. It noted that the Papal Bull of 1911, which created the Kottayam Diocese, was an administrative measure and did not confer any special religious status to enforce endogamy as a binding custom or law. The Court found no credible evidence that endogamy was an immemorial or essential religious practice within Christianity or the Knanaya community. Moreover, it cited the Biblical teaching from Galatians 3:28 emphasizing unity in Christ, underscoring that Christianity does not recognize caste or ethnic distinctions.
The Court rejected appellants’ contention that the Diocese had the right to regulate religious affairs under Article 26(b) of the Constitution of India to enforce endogamy. It held that such rights are subject to constitutional morality, public order, and individual fundamental rights, particularly the right to freedom of religion and conscience under Article 25. The Court emphasized that institutional enforcement of endogamy that leads to excommunication or denial of sacraments violates the individual’s constitutional rights.
Further, the Court upheld the jurisdiction of civil courts to entertain suits alleging violations of fundamental rights by non-state actors, rejecting the argument that only the Supreme Court or High Courts under Articles 32 and 226 have such power. The Court recognized that civil remedies are available to individuals facing coercion or expulsion by religious authorities.
Significantly, the judgment declared that the Kottayam Diocese cannot refuse to solemnize marriages or administer sacraments to members who marry outside the Knanaya community. It also held that spouses and children of such marriages can claim membership and baptismal rights within the Church. The Court granted mandatory and prohibitory injunctions directing the Diocese to cease the discriminatory practice and reinstate members deprived of their rights.
This judgment reinforces the primacy of constitutional rights over internal religious customs that lack essential religious sanction and underscores the protection of individual autonomy within religious communities.
Bottom line:-
The practice of endogamy among the Knanaya Catholic Community does not constitute an essential religious practice, and its enforcement leading to excommunication or denial of sacraments violates constitutional rights under Article 25 of the Indian Constitution.
Statutory provision(s): Constitution of India Articles 25, 26, 29, 32, 226; Code of Civil Procedure Sections 9, 86; Specific Relief Act Sections 4, 35, 39; Travancore-Cochin Literary, Scientific and Charitable Societies Registration Act, 1955 Section 9
