Preserving Sanctity Of Periyar Tiger Reserve Harmonizes With Spiritual Philosophy: Kerala High Court Upholds Regulatory Controls For Sabarimala Pilgrimage Route

The petitioner approached the High Court seeking issuance of a direction to the respondent Authorities not to cause any hindrance to the petitioner and other pilgrims undertaking the Sabarimala pilgrimage through the Traditional Route (Erumeli–Sabarimala Route) from November 15, 2025, so as to reach Sannidhanam when the temple opens for the Mandala season of 2025.

The petitioner also sought interim relief interdicting the respondents from imposing unreasonable restrictions that may hinder or disrupt the peaceful pilgrimage of devotees through the Traditional Route from Erumeli to Sannidhanam, thereby safeguarding their right to freely practice and manifest their religious beliefs.

The Division Bench of Justice Raja Vijayaraghavan V. & Justice K.V. Jayakumar observed, “Protecting the forest and preserving the sanctity of the Periyar Tiger Reserve, therefore, harmonize with, rather than contradict, the spiritual philosophy that underpins Lord Ayyappa’s abode at Sabarimala.”

“...we hold that there is no reason to interfere with the strict regulatory controls imposed by the competent authorities to ensure the safety of pilgrims, conservation of wildlife, and the ecological integrity of the Periyar Tiger Reserve”, it added.

Advocate Mathew A Kuzhalanadan represented the Petitioner, while Sr. GP S. Rajmohan represented the Respondent.

Factual Background

The petitioner, a lawyer and devoted follower of Lord Ayyappa, complained that although he had secured a Virtual Queue (e-pass) for darshan at Sabarimala on November 17, 2025, there was no proper public notification regarding the opening of the Traditional Route (Kanana Patha) from Erumeli to Sannidhanam. The authorities indicated that the route would be opened only on November 17, 2025, which would make it impossible for him and other pilgrims holding e-passes for the same day to undertake the customary forest trek. It was his case that unless the path is opened by November 15, 2025, devotees like him would be forced to abandon the pilgrimage.

The petitioner also highlighted the lack of timely and transparent communication from the Travancore Devaswom Board and the Forest Department, noting that the official portal did not clearly notify the date of opening of the Kanana Patha, causing hardship and frustrating the legitimate expectations of pilgrims who prepare rigorously for the traditional journey.

Reasoning

The Bench took note of the fact that the Traditional Route traversed an ecologically fragile region of significant biodiversity. “It is a matter of concern that no restrictions whatsoever are presently imposed on the number of persons permitted to traverse the Kanana Patha to reach Pamba. When groups comprising hundreds of pilgrims move through this sensitive terrain, serious damage is caused to the Periyar Tiger Reserve”, it stated.

The Bench was of the view that the safety of pilgrims and the preservation of the Periyar Tiger Reserve demand strict adherence to the carrying capacity of the Sannidhanam precincts, the approach and queue management corridors, and the feeder nodes at Pamba and along the Traditional Route.

The Bench held, “The determination of carrying capacity is a technical exercise which, if not already undertaken, must be carried out by the Travancore Devaswom Board in coordination with the District Police, Health Services, Disaster Management Authorities, and the Forest Department. This determination shall be based on scientific parameters such as topography, crowd density thresholds, emergency evacuation capabilities, and ecological sensitivity.”

In view of such facts and circumstances, the Bench asked the Respondents to publish, before the commencement of each Mandala–Makaravilakku season, the computed carrying capacity (including peak simultaneous presence and hourly throughput) for Sannidhanam and each feeder node, along with contingency down-rating for adverse weather or emergency conditions. “The duty of the State to safeguard lives and preserve the environment constitutes a reasonable restriction under this provision. The avowed desire of the pilgrim is to have darshan of Lord Ayyappa and perform the holy rituals. The mode of reaching the temple can be seen as a means to an end, not the end itself”, it noted.

Considering that the traditional route is hallowed by custom, the Bench made it clear that it is not mandated as per any religious tenets or scriptures. Dismissing the petition, the Bench made it clear that there is no reason to interfere with the strict regulatory controls imposed by the competent authorities.

Cause Title: V. Shyamohan v. State Of Kerala (Neutral Citation: 2025:KER:86782)

Appearance

Petitioner: Advocates Mathew A Kuzhalanadan, Kuriakose Varghese, Sradhaxna Mudrika, Nabeel B.A., Cheriyil Sanil John

Respondent: Sr. GP S. Rajmohan, SC G. Biju

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