Sri Venkataramana Devaru v. State of Mysore

Facts

• A temple managed by a religious denomination claimed the right to exclude certain classes of Hindus under Article 26 (right of denominations to manage religious affairs)
• The State of Mysore passed a law allowing all Hindus entry to Hindu temples under Article 25(2)(b)
• The denomination argued the state law violated their Article 26 rights
• Two constitutional provisions appeared to conflict: Article 25 (individual freedom and state power to open temples) and Article 26 (denominational autonomy)

Issue

1. How to reconcile Article 25(2)(b) (state power to throw open temples) with Article 26 (denominational right to manage their own affairs) when both appear to apply to the same situation.

Held

• No constitutional provision should be rendered redundant
• Article 25(2)(b) is a specific provision expressly permitting state laws on temple entry
• Article 26 is a general right to manage denominational affairs
• The specific (Article 25(2)(b)) operates as a qualification on the general (Article 26) to the extent of the specific subject (temple entry)
• Both continue to operate: the denomination retains all management rights except where the specific state law on entry overrides them

Ratio Decidendi

When constitutional provisions appear to conflict, harmonious construction requires identifying the specific and the general. The specific provision prevails on its subject, while the general provision continues to operate in all other areas. Neither provision is rendered redundant; each operates in its respective sphere.