Review Reports - Litigating the Sacred: Legal, Memory, and Spatial Dynamics in Worship Conflicts in Contemporary India

Round 1

Reviewer 1 Report

Comments and Suggestions for Authors

A paper full of potential, on a provoking and timely topic. However, it needs to be clearer conceptually, methodologically, and in terms of the overall argument.

Sections 2 (results) and 3 (discussion) look like draft writing- not full sentences etc. In several places, the paper reads like a draft.

‘Ayodhya’ should be introduced briefly earlier in the paper- not assume readers are familiar it. Perhaps a separate history section would help contextualise the case. Much of the legislation and points of reference are historical- yet the timeframe identified is the Modi era (post 2014).

A separate and distinct literature review would be useful.

The use of headings and sub-headings should be consistent and clear. Same for heading numbering.

The writing on spatial encoding is interesting, but needs better coherence with the rest of the paper. Is the paper primarily about spiritual spaces, or the conflict over the Ram Janmabhoomi temple / Babri Masjid?

p.7 table shows 3 cases of worship conflicts- why select these 3? What do they illustrate?

It is not clear how the proposed materials and methods then translate into the discussion sections- the text and paragraphs appear a little jumbled- better structure would help the reader. What data was collected? How was it analysed? Was a specific framework for analysis used here?

The overall argument of the paper is not clear. The authors should clearly set out their argument, use of data, framework for analysis, and then carefully re-structure the paper. Make a coherent and clearly defined argument, rather than try to cover too much ground.

Author Response

Response to Reviewer 1 Comments

1. Summary

We are very grateful for your thoughtful and constructive comments, which have been extremely helpful in revising and sharpening the article. Below we respond point by point and indicate how the current version has been modified accordingly.

Point-by-point response to Comments and Suggestions for Authors

Comment 1: A paper full of potential, on a provoking and timely topic. However, it needs to be clearer conceptually, methodologically, and in terms of the overall argument.

Response 1: We thank you for this generous assessment and for urging us to clarify the conceptual and methodological architecture of the paper. In the revised version: The Introduction has been rewritten to more clearly set out the theoretical lenses (Durkheim, Eliade, Geertz, Lefebvre, etc.), the core research question, and the central argument that worship-site litigation has become a key site for re-negotiating India’s secular constitutional order. The final paragraph of the Introduction now explicitly states the article’s three-step structure (Ayodhya and the Places of Worship Act; comparative analysis of three temple–mosque disputes; and constitutional implications for secular adjudication), so that the reader knows “what is going to happen” in the paper. We have also clarified the methodological approach as a qualitative, socio-legal and doctrinal analysis based on close reading of case law, statutory texts, parliamentary debates, media reports and secondary scholarship. This is now signposted in the Introduction and in the opening of Parts II and III, so that the link between framework and later discussion is more transparent.

Comment 2: Sections 2 (results) and 3 (discussion) look like draft writing – not full sentences etc. In several places, the paper reads like a draft.

Response 2: We fully agree that the earlier “Results” and “Discussion” sections reflected a hurried attempt to adapt the MDPI template and did not match the conventions of a humanities/socio-legal article. Following your suggestion, we have: Completely removed the separate “Results” and “Discussion” headings from the early part of the article. Restructured the body of the paper into four substantive Parts with clear, humanities-style headings: I. The Generative Logic of Judicialization in India’s Worship-Place Disputes; II. Notable Cases of Judicialization in Worship-Place Disputes; III. Judicialization of Sacred Spaces: Constitutional Dilemmas in Secular Adjudication; IV. Secular Adjudication under Strain. Within these Parts, we now use sub-sections (i), (ii), (iii) with full, polished paragraphs, and have removed fragmentary or draft-like bullet points.We have retained the underlying analytical content that had been placed under “Results/Discussion”, but it is now integrated into Parts II–IV in a more coherent narrative form.

Comment 3: ‘Ayodhya’ should be introduced briefly earlier in the paper – not assume readers are familiar with it. Perhaps a separate history section would help contextualise the case. Much of the legislation and points of reference are historical – yet the timeframe identified is the Modi era (post 2014).

Response 3: We appreciate this point and have made two main changes: Earlier introduction and dedicated historical section: The Introduction now briefly explains why Ayodhya is central to debates about sacred space and secularism in India. Part I(i) “The Ripple Effect of the Ayodhya Verdict” has been reworked into a concise historical and legal background section on Ayodhya: colonial regulation, the 1949 idol placement, the 1992 demolition, ensuing riots, and the Supreme Court’s 2019 judgment. This gives readers unfamiliar with the case a clear starting point. Clarified temporal framing: We now state more explicitly that the article is anchored in the post-2014 Modi era, but analytically places recent developments within a longer genealogy of colonial and post-colonial governance of worship sites. This is signalled in the Intro and in Part I, so that the historical references (e.g. 1991 Act, 1958 AMASR Act) are clearly positioned as the institutional background to contemporary developments.

Comment 4: A separate and distinct literature review would be useful.

Response 4: We have strengthened and partially restructured the Introduction so that it now functions as a clear literature review: One paragraph now summarises earlier work on Ayodhya and related episodes, including analyses of mobilisation and violence (Qiu; Bacchetta; Gort; Wilkinson; Rao; Kumar). A second cluster of references deals with Hindu nationalism and Hindutva and the use of sacred spaces in majoritarian politics (Sharma; Jaffrelot; Brass). A third set covers legal–historical studies of the Babri Masjid dispute and the Places of Worship Act (Noorani; Rao; Srikantan 2012, 2020; Srivastava & Gaurha). The final sentences of the literature review explicitly identify the gap – a heavy focus on Ayodhya and earlier mobilisation phases – and position this article as an update that tracks post-2019 judicialisation and comparative case patterns. Thus, while we do not label it as a standalone “Literature Review” section (in line with many humanities journals), the introduction now clearly performs that function.

Comment 5: The use of headings and sub-headings should be consistent and clear. Same for heading numbering.

Response 5: We have undertaken a thorough re-organisation of headings: Main parts are now labelled I, II, III, IV with informative titles. Sub-sections use (i), (ii), (iii) consistently. Numbering is uniform throughout the article; we have removed hybrid or template-driven labels such as “Section 2 – Results”. Headings now accurately track the argument: from generative logic and case studies to constitutional dilemmas and forward-looking secularism questions.

Comment 6: The writing on spatial encoding is interesting, but needs better coherence with the rest of the paper. Is the paper primarily about spiritual spaces, or the conflict over the Ram Janmabhoomi temple / Babri Masjid?

Response 6: This was very helpful in prompting us to clarify the role of the “spatial” discussion. We have: Reframed Part I(ii) “The Inalienability and Perpetuity of Worship Places” to emphasise that the theoretical discussion of sacred space, spatial encoding and inalienability is instrumental to understanding why certain sites (Ayodhya, Kashi, Mathura, etc.) later generate legal claims about perpetuity and non-substitutability. Added a linking paragraph at the end of I(ii) that explicitly states how these features of sacred spatiality feed into later legal doctrines and claims (e.g. juristic personality of deities, inalienability, continuity of worship), which are then taken up in Parts II–IV. Made clear that the paper is not only about the Ram Janmabhoomi/Babri Masjid conflict, but uses Ayodhya as a generative case and then moves to other disputes (Gyanvapi, Shahi Idgah, Jama Masjid, and the Places of Worship Act litigation) to show how similar logics operate elsewhere. We hope this makes the coherence between “spatial encoding” and the legal-political analysis more evident.

Comment 7: p.7 table shows 3 cases of worship conflicts – why select these 3? What do they illustrate?

Response 7: We have revised Part II(i) “Comparative Analysis of Worship-Place Disputes” to explicitly justify the case selection: The text now explains that the Gyanvapi Mosque (Varanasi), Shahi Idgah Mosque (Mathura), and Jamia Masjid (Srirangapatna) were chosen because they: Operate under different statutory regimes (Places of Worship Act, AMASR Act, Waqf Act); Emerge from distinct regional and political contexts (Uttar Pradesh vs Karnataka); and Display a range of judicial and administrative techniques (court-ordered surveys, ASI involvement, interim worship orders, heritage-protection arguments). We state that, read together, they illustrate recurrent adjudicatory patterns: reconstruction of historical narratives, reliance on archaeological or expert evidence, and the assertion of civil/public-law remedies.The caption and lead-in to Table 1 now emphasise that the table is comparative and illustrative, not exhaustive.

Comment 8: It is not clear how the proposed materials and methods then translate into the discussion sections – the text and paragraphs appear a little jumbled – better structure would help the reader. What data was collected? How was it analysed? Was a specific framework for analysis used here?

Response 8: We have acted on this critique in several ways: As noted above, we removed the early “Results/Discussion” headings that were artefacts of the MDPI general template and that contributed to the impression of a “jumbled” structure. The article now follows a clear narrative progression (I–IV), signalling at each step how the analytical framework is being applied. We have made the data sources and method more explicit, indicating that the analysis is based on: Close reading of Supreme Court and High Court judgments, Examination of relevant statutes (Places of Worship Act, AMASR Act, Waqf legislation, etc.), Select parliamentary debates (e.g. Lok Sabha discussion of the 1991 Act), Media reports on recent disputes and survey-related clashes, A body of secondary scholarship on secularism, sacred space and Hindutva. The interdisciplinary framework is now explicitly described as combining: Theoretical work on sacred space and social integration; Socio-legal analysis of judicialisation and rule-of-law practices; Contextual reading of political and nationalist discourse. We hope this addresses your concern that the earlier version did not sufficiently connect “methods” to the subsequent analysis.

Comment 9: The overall argument of the paper is not clear. The authors should clearly set out their argument, use of data, framework for analysis, and then carefully re-structure the paper. Make a coherent and clearly defined argument, rather than try to cover too much ground.

Response 9: We have made a concerted effort to sharpen and foreground the main argument: The last paragraph of the Introduction now states the core claim: that the judicialisation of worship-place disputes after the Ayodhya verdict has become a central mechanism through which the boundaries between religious symbolism and secular legality are being renegotiated, with implications for India’s secular constitutional order. The structure of Parts I–IV tracks this claim step by step: I identifies the generative logics (sacred space, inalienability, political mobilisation); II examines three concrete disputes to show how those logics operate in practice; III situates these patterns within constitutional secularism and legal frameworks; IV analyses the strains on secular adjudication and forward-looking implications (including the constitutional challenge to the Places of Worship Act). The Conclusion has been rewritten to directly restate the argument and to draw out its implications for debates on secularism, historical justice, and minority protection in plural societies.

We hope that, with these changes, the article now presents a more focused and clearly articulated argument, while still retaining the broader contextual richness that the topic demands. Once again, we are very grateful for your detailed and constructive review. Your comments substantially improved the clarity, structure and argumentative precision of the paper.

Reviewer 2 Report

Comments and Suggestions for Authors

This article has potential to be an engaging work given a more reader-friendly style and clear organization. There are challenges for the reader to be able to follow the evidence and reasoning. There are confusing subsections that appear as partial sentences, and sections with titles appropriate for a social science research involving empirical studies (Results, Discussion, etc.).

Comments on the Quality of English Language

The language is very rich, but also overly technical and cumbersome. More effort into putting things simply in a logical manner will help. There are drastic differences between the first part of the essay and later parts in terms of using complete sentences to express ideas.

Author Response

Response to Reviewer 2 Comments

We thank you for the careful reading and constructive comments. We appreciate the emphasis on clarity, organisation, and accessibility, and have undertaken substantial revisions to address these concerns. Below we respond point by point.

Comment 1: This article has potential to be an engaging work given a more reader-friendly style and clear organization. There are challenges for the reader to be able to follow the evidence and reasoning.

Response 1: We are grateful for this assessment and agree that the earlier version did not always guide the reader clearly enough. In the revised manuscript we have: Reorganised the structure into four clearly signposted main parts (I–IV), each with descriptive titles that indicate its function in the overall argument.

Added explicit roadmap sentences in the Introduction, explaining that the article proceeds in three steps: (1) tracing the "ripple effects" of the Ayodhya judgment and situating the Places of Worship Act, 1991; (2) offering a comparative analysis of three temple–mosque disputes; and (3) examining the constitutional dilemmas of secular adjudication. At the start of each major section, we now clearly state what the section will do (e.g. conceptual background, case analysis, constitutional framing) and how it connects to the preceding material. These changes are intended to make the progression of evidence and reasoning more transparent and reader-friendly.

Comment 2: There are confusing subsections that appear as partial sentences, and sections with titles appropriate for a social science research involving empirical studies (Results, Discussion, etc.).

Response 2: We fully agree that the earlier use of "Results" and "Discussion" headings, and some fragmentary subsections, created confusion. These headings were originally added hastily in an attempt to comply with the generic MDPI template, but we recognise that they were not appropriate for a humanities / socio-legal essay. In the revised manuscript: The "Results" and "Discussion" sections have been completely removed. Their substantive content has been redistributed into the new Parts II–IV and reworked into coherent paragraphs. All subsections that previously appeared as partial sentences or bullet-style notes have been rewritten as full, polished prose, with topic sentences and clear transitions. The remaining headings now follow a consistent hierarchy (main parts I–IV; subsections (i), (ii), (iii)), and each subsection title accurately reflects its content. We hope this addresses the concern about draft-like structure and aligns the article more clearly with humanities conventions.

comment (form) 3: Are the research design, questions, hypotheses and methods clearly stated? – Must be improved.

Response 3: We acknowledge that the earlier version did not sufficiently spell out the research design and methods. We have now: Added a concise "methods and approach" explanation in the Introduction, indicating that the article is based on: doctrinal analysis of Supreme Court and High Court judgments; examination of statutory frameworks (Places of Worship Act, AMASR Act, Waqf legislation, etc.); reading of parliamentary debates and media reports; and engagement with secondary scholarship on secularism, sacred space, and Hindu nationalism. Clarified that the article uses an interdisciplinary socio-legal framework, combining theories of sacred space and social integration with constitutional and doctrinal analysis. Reformulated the guiding research question as: how the judicialisation of disputes over places of worship, especially in the wake of the Ayodhya judgment, is reconfiguring the practice of secular adjudication in India. These clarifications are meant to give the reader a clearer sense of "what kind of study this is" and how the materials are being analysed.

comment (form) 4: Are the arguments and discussion of findings coherent, balanced and compelling? – Can be improved.

Response 4: We appreciate this suggestion and have made several changes to improve coherence and balance: The central argument is now stated more explicitly in the Introduction and revisited in the Conclusion: that courts, through the management of worship-site litigation, are simultaneously stabilising and reshaping India's secular order, and that this process generates tensions around neutrality, historical justice, and minority protection. We have trimmed or moved material that was tangential or overly speculative, in order to keep the discussion focused on the main line of argument. Sections that deal with Hindu nationalism and "Judicial Hindutva" have been rewritten in a more analytical and cautious register, with clear attribution to specific commentators and sources, and with greater emphasis on institutional trade-offs rather than political slogans. Throughout Parts III and IV, we have tried to present both risks and possible safeguards (for example, how archaeological evidence can both narrow interpretive space and, in other views, provide structured procedures for handling contentious claims), in order to maintain a balanced perspective. We hope these revisions make the argumentative thread easier to follow and more persuasive.

comment (form) 5: For empirical research, are the results clearly presented? – Can be improved.

Response 5: Although the article is not an empirical study in the strict social-scientific sense, we understand this concern as relating to how the case analyses and doctrinal findings are presented. To address this: We have clarified the role of Part II ("Notable Cases of Judicialization in Worship-Place Disputes") as the section where the main "findings" from case analysis are presented. The discussion of the three disputes (Gyanvapi, Shahi Idgah, Jama Masjid in Srirangapatna) is now organised under a clear comparative logic, supported by a revised table that summarises their legal frameworks, evidentiary strategies, judicial approaches, and political framings. Each case discussion now concludes with one or two sentences explicitly stating what the case illustrates, so that the reader can see how it feeds into the broader argument rather than standing as a loose vignette.

comment (form) 6: Is the article adequately referenced? – Can be improved.

Response: We have systematically reviewed and strengthened the referencing: All works mentioned in the text are now included in the References section, formatted consistently in Chicago style, including full details for books, articles, working papers, and web sources. We have added citations where earlier drafts used more general phrases like "commentators argue…", especially in sections on the Places of Worship Act, Hindutva narratives, and Ayodhya-related critique. The literature review in the Introduction has been expanded and better structured, distinguishing among: (a) work on Ayodhya and Hindu–Muslim violence; (b) scholarship on Hindu nationalism and sacred space; and (c) legal–historical studies of worship-site regulation. These changes are intended to situate the article more clearly within existing scholarship and to make the engagement with previous literature more visible.

Comment 7: The language is very rich, but also overly technical and cumbersome. More effort into putting things simply in a logical manner will help. There are drastic differences between the first part of the essay and later parts in terms of using complete sentences to express ideas.

Response 7: We appreciate this candid feedback and have undertaken extensive language editing with your comments in mind: We have simplified and shortened many sentences, especially in the theoretical and constitutional sections, while retaining necessary nuance. Dense phrases and excessive nominalisations have been reduced. Sections that were previously overly technical or phenomenological (for example, parts of the discussion on sacred space) have been rewritten in plainer, more direct language and more tightly tied to the legal analysis. We have carefully checked the entire manuscript for uniform use of complete sentences, particularly in the later sections where some draft-like constructions remained. We have also tried to harmonise the register across the article, so that the opening and later parts now match in terms of clarity and style.

We hope that the revised version reads more smoothly and that the richness of the language now serves, rather than obscures, the argument. Once again, we thank you for these helpful suggestions. They have significantly improved the clarity, structure, and accessibility of the article.

Reviewer 3 Report

Comments and Suggestions for Authors

“Litigating the Sacred: Legal, Memory, and Spatial Dynamics in Worship Conflicts in Contemporary India” has been a difficult paper to assess as a peer reviewer. On the one hand, the paper provides an incisive blueprint for how Hindu nationalism has operated within litigation and judicial processes in property conflicts involving Hindus and Muslims in contemporary India. On the other hand, the paper's delivery suffers on account of some baffling structural decisions, most notably the inclusion of sections for “Results” and “Discussion” in the first three pages of the paper (in point form, no less). On account of these sections, which will need to be deleted or substantially rewritten, I have no choice but to recommend major revisions for this paper. It pains me to suggest as much, because the rest of this paper is well written, making a stellar contribution to the literature regarding the legal consequences of Hindutva.

The paper begins with a fairly strong introduction laying out the theoretical lenses for the paper. However, its concluding paragraph (lines 45-49) is a bit too general in nature. It would be beneficial for the author(s) to talk more concretely about what's going to happen in the paper to follow. I think it is absolutely necessary that the introduction provides some information about the sites other than the Babri Masjid that are going to be discussed in tabular form later on (i.e. the mosques at Gyanvapi, Shahi Igdah, and Jama). This will provide some much-needed context for the discussion to follow. Also, the author gives little sense of the layout of the rest of the paper in the intro, which makes the immediate transition into the “Results” and “Discussion” sections somewhat jarring.

I would strongly recommend removing the “Results” and “Discussion” sections. “Results” and “Discussion” sections are something I associate with the end of a paper, not page two. Perhaps a science paper might place these sections early on, but this kind of layout really does not work for a humanities essay. Perhaps the author (or authors) is trying to stick to the general manuscript guidelines provided by MDPI (admittedly, these threw me off the first time I submitted a paper via this website, too). Whatever the case, I think these sections can be omitted, as the results were solidly established in the further discussion of the paper. The author(s) can keep the “Materials and Methods” section.

If the author is absolutely adamant upon keeping the “Results” and “Discussion” sections, then these should be moved to the end of the paper. Certainly, if included in the paper, they should follow the “Materials and Methods” sections. In the present draft, the “Results” and “Discussion” do not really benefit from any of the context of the methodology, and so it is hard for the reader to understand their implications. And, if kept, these sections should be rewritten in full sentences rather than point form. But again, I implore the author(s) to eliminate the “Results” and “Discussion” sections.

Additionally, there are two instances of doubled passages that need to be removed. Firstly, lines 258 to 265 closely resemble lines 219 to 230 (on the interaction between religious worship places and political power). Secondly, lines 266 to 273 closely resemble lines 231 to 240 (on the evolution of nation states). In each case, the author should remove the second instance of the passage and work diligently to smooth the transitions between the remaining paragraphs. This revision will involve careful deliberation about where to include lines 273 to 276, which still retain some utility for the section. Perhaps that passage should appear after line 240; this, however, is a decision to be made by the author.

Even though the removal of sections and redundant passages constitutes a major revision, the paper still succeeds in arguing its thesis, and provides another strong line of evidence for how Hindu theology and Hindutva ideology have infiltrated the Indian legal system. Once these changes, albeit major, are made, the paper will be eminently publishable with just a few additional cosmetic fixes. I will now proceed with my minor suggestions in line-by-line fashion.

120-127: This is an odd use of square brackets. I'd recommend turning this parenthetical statement into an endnote or footnote. Also, there's a superfluous space in front of “The” in line 120.

128: Make your headings clearer. It would appear that “The Generative Logic of Judicialization in India's Worship Place Disputes” appears under “Materials and Methods.” This isn't ideal, so please do make the headings more obvious and make the numbering clearer (that is, moving from upper-case Roman numerals to lower-case on the next level; on a related note, see my comment on line 346 below).

134: Add a space between “mosque” and “(supreme [...]”

136: Add a space after the period and after the comma following “Xuejiao”.

158: Add a space between “space.” and “Because”.

162: Add a space after “quo.”

163: man → humans [be gender neutral]

164: The em-dashes surrounding “the center” should be longer.

165: Add a space after “construction”. Also, put the period after the citation.

169: Add a space after “dimension.”

182: Add a space after “order”.

191: Put the period after the citation.

221: What do you mean by “traditional societies”? Give a bit more detail.

226: Delete the period after “strategies”.

254: Delete the period after “rights”. Add a space after “litigation.”

346: Instead of (I), use (i) for added clarity in your subheadings.

351: Put the period after the citation.

355-356: Put the period after the citation.

374: Capitalize “but” and add a space in front of it. Also, capitalize “india”.

376-377: Add a space after “social agendas” and delete the superfluous space in front of “Clemens”.

386: Eliminate superfluous space after “religion"”.

388: Eliminate extra period after “sites.”

413: Shouldn't “IV. Secular Adjudication under Strain” be in bold? Again, be very conscientious with these headings.

417-418: Put the period after the citation.

451-453: You mention “some observers as indicating a partial convergence between judicial activism and Hindu-nationalist politics” in this passage. You should include a citation here so we know who these “observers” are.

484: Delete additional period after “courtroom.”

530: Add a space after “example.”

541: It → it

References: Italicize titles of books. Also, some of the references spill over into the next line without hyphenation (e.g. Anderson, Chatterjee, and others). Please fix these. The period at the end of the Qiu reference looks to be misplaced. Also, it appears you've lumped all your internet sources at the end of reference list. They might be more effective if they're under a subheading (e.g. “Online Sources”) or else mixed in with the print materials in alphabetical order.

Author Response

Response to Reviewer 3 Comments

summary

We are very grateful to you for the careful, generous, and insightful report. We especially appreciate the comment that, once revised, the paper "will be eminently publishable" and "makes a stellar contribution to the literature regarding the legal consequences of Hindutva." We have undertaken a thorough revision of the manuscript in light of these suggestions. Below we respond point by point.

Point-by-point response to Comments and Suggestions for Authors

Comment 1: The inclusion of "Results" and "Discussion" sections at the beginning of the paper is structurally confusing and more appropriate to a natural-science article than to a humanities essay. These sections should be deleted or substantially rewritten.

Response 1: We fully agree. In the original submission we followed the generic MDPI template rather mechanically and, in the rush of submission, retained "Results" and "Discussion" headings in a way that was not appropriate for a humanities article. In the revised manuscript: The "Results" and "Discussion" sections have been completely removed. The argument is now structured in a conventional humanities format: Introduction → Sections I–IV (with thematic subsections) → Conclusion. Material that had been placed in "Results" and "Discussion" has been redistributed and rewritten as continuous prose, integrated into Section I ("The Generative Logic of Judicialization…") and the later analytical sections. We very much appreciate your understanding of how the MDPI template can mislead first-time contributors, and we have now aligned the structure with standard expectations in religious studies and socio-legal scholarship.

Comment 2: The introduction is generally strong but ends too generically, without clearly indicating what will follow. It should more concretely state what the paper will do, and introduce the sites other than Babri Masjid (Gyanvapi, Shahi Idgah, Jama Masjid in Srirangapatna) that are analysed later.

Response 2: We have substantially revised the concluding paragraph of the Introduction. The revised version now: Sets out a three-step roadmap of the argument (Ayodhya and the Places of Worship Act → comparative analysis of three temple–mosque disputes → constitutional dilemmas of secular adjudication). Explicitly names the three non-Ayodhya cases—the Gyanvapi Mosque proceedings in Varanasi, the Shahi Idgah dispute in Mathura, and the Jama Masjid litigation in Srirangapatna—and briefly explains why they are selected. Clarifies how these cases feed into the later comparative table and the broader argument about judicialisation and secularism. This addresses the reviewer's concern about a "jarring" transition and provides the reader with a clearer sense of what the paper will do.

Comment 3: There were two sets of duplicated or near-duplicated passages (on the interaction between religious worship places and political power; and on the evolution of nation-states) that should be removed and the remaining text smoothed.

Response 3: We have carefully removed the redundant passages identified by the reviewer and restructured the surrounding text: The discussion of worship places and political power now appears once, in a refined form, at the beginning of Section I(iii) "Political Mobilization Dynamics in Litigation Processes." The discussion of the transition to nation-states and the incorporation of religious sites into legal frameworks has been consolidated and placed in Section I(iii) and Section III(ii), avoiding duplication. We then worked through the transitions between paragraphs, so that the remaining material on colonial governance, nation-state formation, and secular legal incorporation reads as a single coherent thread rather than as repeated blocks.

Comment 4: "What do you mean by 'traditional societies'?"; "man → humans [be gender neutral]."

Response 4: We have made both conceptual and stylistic changes: In Section I(iii), the phrase "In traditional societies" has been replaced with "In many re-modern polities", and the paragraph now explicitly explains how sacred spaces functioned as hubs of social power and governance. In the discussion of Mircea Eliade, we now write "the 'religious human being' (often rendered as 'religious man')", thereby both adopting gender-neutral language and acknowledging the historical terminology. These adjustments respond directly to the reviewer's concerns and clarify the intended meaning.

Comment 5: Headings and sub-headings should be clearer and consistently numbered; e.g. use (i) rather than (I) for subheadings; "IV. Secular Adjudication under Strain" should be formatted consistently; be conscientious with headings.

Response 5: We have systematically revised the heading structure throughout the manuscript: Top-level sections now appear as I, II, III, IV. Subsections within each are consistently formatted as (i), (ii), (iii) (rather than mixing (I)/(i)). Section titles such as "IV. Secular Adjudication under Strain" are formatted in the same style (bold, consistent font and size). We have also double-checked that the heading hierarchy matches the argument's conceptual structure. In addition, we have carefully gone through the line-by-line formatting issues mentioned by the reviewer (spaces after citations, punctuation placement, double periods, stray spaces, etc.) and corrected them globally, rather than only at the specific lines cited. This includes: moving periods to follow citations, adding or removing spaces where needed, correcting em-dashes and quotation marks, and ensuring consistency in the placement of URLs and access dates.

Comment 6: The writing on spatial encoding is interesting but needs better coherence with the rest of the paper; is the paper primarily about spiritual spaces or about the Ram Janmabhoomi / Babri Masjid conflict?

Response 6: We have kept the phenomenological discussion of sacred space (Eliade, spatial encoding, gopuram, etc.) but tightened and re-anchored it to the legal argument: The relevant subsection now begins with a clarifying sentence explaining that this discussion is offered "in broad terms… to explain why specific worship sites can come to be treated as inalienable and perpetual in later legal arguments." The final paragraphs of that subsection explicitly link the non-substitutability and cosmological meaning of particular sites to later legal claims of inalienability, perpetuity, and continuity of worship. This makes it clearer that the phenomenological material is not a free-standing detour, but provides the conceptual grounding for why certain places of worship are litigated as unique, inalienable entities in Indian courts.

Comment 7: Where the manuscript refers to "some observers" or similar, citations should be specified.

Response 7: We have revised such passages in two ways: In several instances, vague phrases such as "some observers" or "commentary has noted" have been replaced with more precise formulations (e.g. "a range of commentators have interpreted…") and accompanied by citations, such as Jaffrelot (1998; 2021), Sharma (2016), Srivastava and Gaurha (2021), and Supreme Court Observer (2023; 2025). here we refer to public discourse labels such as "Judicial Hindutva", we now explicitly signal that these are contested analytic terms and ground the discussion in scholarly treatments (e.g. Jaffrelot 1998, Bhargava 1998). We have also expanded and standardised the reference list in Chicago style, italicising book titles and ensuring consistency for journal articles and online sources.

Comment 8: A series of line-by-line suggestions regarding spaces, punctuation, capitalisation ("India"), and reference formatting; book titles should be italicised; web references could be grouped or clearly distinguished.

Response 8: We are grateful for this meticulous level of attention. In response, we have: Italicised all book titles in the reference list and corrected small issues with line breaks and punctuation. Ensured that internet sources are clearly identified and formatted in Chicago style, and that the in-text citations match the reference entries (e.g. harmonising "Supreme Court Observer 2025" in text and in the bibliography). Reviewed the whole manuscript for the kinds of minor infelicities identified (extra spaces, mis-placed periods, doubled quotation marks, etc.), not just at the lines mentioned.

Once again, we thank you for the extremely constructive and encouraging report. The comments have significantly improved the clarity, structure, and precision of the paper. We hope that the revised version addresses all concerns and that the strengthened argumentation and organisation will now be satisfactory.

Round 2

Reviewer 1 Report

Comments and Suggestions for Authors

This paper is significantly improved from the previous version. However, it still needs work to tighten the theoretical argument and clarify the contribution to the scholarly field.

The literature review is not really critical enough- it mentions several key debates across relevant topics, but doesn’t critically interrogate them sufficiently. The narrative flow of sections and sub-sections has improved, but is still a bit confusing. Why is the article laid out like this?

Starting p.6, Table 1 would be better presented as full text- the table is very dense and a complex series of points and arguments are given here but not analysed fully- nor exactly how they add to the Ayodhya case or the paper’s overall argument. Of hundreds of possible contested sites, why are these 3 selected? What factors connect these 3 with Ayodhya, and why not mention many of the other possible sites? For example, India has multiple religions- why do all the cases mentioned here feature Muslim-Hindu disputes?

“When archaeological or textual narratives are advanced to reinterpret a site's past, some Muslim stakeholders experience this as challenging both the material fabric of Islamic architecture and established mnemonic anchors”- what evidence for this? Which Muslims exactly? Similarly on 283: “certain groups seek to strategically navigate or narrow the Places of Worship Act”- which groups? How do the authors know this?

What is new in this paper? What is being presented here than has not previously been written or investigated? Overall, while there is nothing significant here that an informed reader would disagree with, it remains unclear exactly what is the paper’s main argument and theoretical contribution. There are historical origins for modern faith-based contestations, and complex and even contradictory legislation, and religious buildings blend secular and sacred space- yes, but then what is this paper’s original contribution?

Some feedback from the previous version relates to lack of detail about what data has been collected, the methodological approach used here, and the analytical framework. This newer version unfortunately does not adequately address these shortcomings.

Author Response

Response to Reviewer 1 Comments (Round 2)

1. Summary

We are very grateful for your careful reading of the revised manuscript and for the detailed comments, which have been extremely helpful in sharpening the article’s argument, structure, and methodological self-presentation. Below we respond point-by-point to your observations and indicate how we have revised the manuscript accordingly.

Point-by-point response to Comments and Suggestions for Authors

Comment 1: “This paper is significantly improved from the previous version. However, it still needs work to tighten the theoretical argument and clarify the contribution to the scholarly field… What is new in this paper? What is being presented here than has not previously been written or investigated? … it remains unclear exactly what is the paper’s main argument and theoretical contribution.”

Response 1: Thank you for this important critique. In the revised manuscript we have: (1) Clarified the core argument in the Introduction. We now state more explicitly that the article’s central claim is that contemporary worship-place disputes in India instantiate a process of “judicialized sacred space”, in which long-standing sites are reworked—through litigation, evidentiary practices, and administrative techniques—into juridical objects and political stakes. (2)Spelled out the article’s three main contributions in a concise “contributions” paragraph. The Introduction now contains a short, explicit statement that the article: (i) develops the notion of judicialized sacred space as a way of analyzing the interaction between sacred space, legal techniques, and political projects; (ii) moves beyond Ayodhya by offering a comparative analysis of three high-salience post-2019 cases (Gyanvapi, Mathura, Srirangapatna) in different statutory settings; and (iii) shows how archaeological surveys, narrative reconstructions of a site’s past, and procedural categories are mobilized across these disputes, thereby foregrounding the shifting institutional role of the Archaeological Survey of India (ASI) and the higher judiciary. (3)Linked theory to the analytical framework more tightly. The section on sacred space and inalienability has been reworked into a three-part analytical framework, treating places of worship as: (i) indivisible sacred spaces (Hassner) whose perceived non-substitutability underpins claims of inalienability and perpetuity;
(ii) produced spaces (Lefebvre) in which legal, ritual, and political practices jointly constitute the site as a juridical object; and (iii) mnemonic anchors for competing historical narratives and group identities.

We hope these revisions make the article’s original contribution clearer: it offers a conceptually informed, institution-focused account of how post-Ayodhya worship-place disputes are structured and reproduced through legal techniques, evidentiary practices, and statutory regimes, rather than simply reiterating that “politics and religion are intertwined.”

Comment 2: “The literature review is not really critical enough- it mentions several key debates across relevant topics, but doesn’t critically interrogate them sufficiently. The narrative flow of sections and sub-sections has improved, but is still a bit confusing. Why is the article laid out like this?”

Response 2:
We appreciate this prompt to sharpen the literature review and clarify the structure. (1) More critical literature review. In the Introduction we now group the literature into three strands: (a) work on sacred sites, ritual, and religious architecture (Durkheim, Eliade, Geertz, Lefebvre, etc.); (b) political science and historical work on Ayodhya, Hindutva mobilization, and communal violence; (c) legal-historical work on the Babri Masjid litigation, the Places of Worship Act, 1991, and related statutes. For each strand we briefly indicate not only what the works have shown, but also where they leave gaps—particularly regarding the legal-institutional mechanics of post-2019 disputes, the role of ASI and courts as evidentiary arbiters, and the comparative dimension beyond Ayodhya. We then explicitly note that much of the existing work “tends to foreground political mobilization while paying less attention to the legal and institutional techniques through which such projects are pursued,” which sets up the article’s distinct focus. (2) Clearer explanation of structure. At the end of the Introduction we added a short paragraph that explains the article’s layout: a conceptual section on sacred space and inalienability; a section on the legal and institutional framework; the three case studies; and an analytical evaluation that draws out cross-cutting patterns and implications.

We hope these changes make both the positioning within the literature and the internal narrative flow more explicit and easier to follow.

Comment 3: “Starting p.6, Table 1 would be better presented as full text- the table is very dense and a complex series of points and arguments are given here but not analysed fully- nor exactly how they add to the Ayodhya case or the paper’s overall argument. Of hundreds of possible contested sites, why are these 3 selected? What factors connect these 3 with Ayodhya, and why not mention many of the other possible sites? For example, India has multiple religions- why do all the cases mentioned here feature Muslim-Hindu disputes?”

Response 3: We have substantially reworked this part of the paper in three ways: 1. Restructuring the table and adding narrative analysis. The earlier dense table has been replaced with a more compact comparative table that focuses on three core dimensions for each case: legal framework, key evidence/claims, and procedural posture. A separate subsection, “Analytical Evaluation of the Cases,” now draws out the recurring patterns across the three disputes and explicitly links them back to the article’s overarching argument and theoretical framework. 2. Justifying the selection of the three cases. We have added a dedicated paragraph explaining why these three disputes (Gyanvapi, Mathura, Srirangapatna) were selected: they are among the most high-salience and legally consequential post-2019 disputes; they collectively span different statutory regimes; in each case, litigants and commentators explicitly invoke, or are read through, the lens of Ayodhya, treating it as a template or counterpoint. We also emphasize that the aim is not to map all contested sites, but to analyze a bounded set of legally and politically influential disputes that illuminate broader patterns of judicialization. 3. Explaining the focus on Hindu–Muslim disputes and acknowledging other configurations. In the introduction to the case section, we now explicitly acknowledge other types of contestation involving Jain, Buddhist, Sikh, and indigenous traditions (for example, over Jain pilgrimage hills such as Sammed Shikharji/Parasnath and Shatrunjaya, over shared Hindu–Sufi shrines such as Baba Budangiri/Datta Peetha, and over Buddhist control of Bodh Gaya/Mahabodhi), and briefly note the distinct legal constellations in which they are embedded. In the course of revising the manuscript, I also worked through Bodh Gaya/Mahabodhi as a potential additional case study and conducted a more systematic review of that dispute. However, I ultimately decided not to incorporate it into the main case section, as doing so would have made the article’s structure more diffuse and shifted the focus away from the specifically post-Ayodhya phase of worship-place litigation that the article aims to analyze. We therefore explain that the present article focuses on Hindu–Muslim disputes because these are the primary context in which the Places of Worship Act, 1991 has been directly invoked and contested, and where appeals to “historical justice” and “correcting past wrongs” have been most systematically channeled through litigation in the wake of the Ayodhya judgment. We further note that other configurations (such as Jain–state conflicts over sacred hills or Hindu–Sufi shared shrines) raise analytically distinct questions and deserve separate, more sustained treatment..

We hope these revisions address your concern about case selection and make the scope and focus of the article more transparent.

comment 4: “‘When archaeological or textual narratives are advanced to reinterpret a site's past, some Muslim stakeholders experience this as challenging both the material fabric of Islamic architecture and established mnemonic anchors’- what evidence for this? Which Muslims exactly? Similarly on 283: ‘certain groups seek to strategically navigate or narrow the Places of Worship Act’- which groups? How do the authors know this?”

Response: Thank you for drawing attention to the lack of precision in these formulations. We have revised the manuscript to (i) specify the actors more clearly and (ii) anchor the claims more explicitly in identifiable sources. (1) On “some Muslim stakeholders”. The earlier phrase has been replaced with a more precise formulation that identifies the relevant actors and ties the point to concrete disputes. We now refer to “mosque committees, waqf boards, and Muslim organizations in disputes such as those over Gyanvapi and Mathura” and describe how they have, in their pleadings and public statements, framed archaeological or textual attempts to reinterpret a site’s past as challenging both the built fabric of mosques and established patterns of worship and remembrance. We have also added references (in the main text and footnotes) to specific court documents and media reports where these concerns are articulated, so that it is clear which actors we are referring to and on what evidentiary basis. (2) On “certain groups seek to strategically navigate or narrow the Places of Worship Act”. Here, the earlier wording “certain groups” has been replaced with “Hindu litigants and aligned organizations in cases such as Gyanvapi and Mathura”, making explicit that our claim concerns identifiable parties in specific worship-place disputes rather than an undefined category. We now ground this observation in (a) pleadings and petitions that seek to reopen questions of “religious character” or to obtain surveys despite the 1991 Act, and (b) public statements by Hindu nationalist organizations and politicians who present these suits as efforts to correct “historical wrongs” or to revisit the statutory status quo. These sources are now cited in the footnotes and discussed in the text. In addition, we have slightly softened the phrasing to acknowledge that this is, in part, a matter of interpretation: we now write that these actors have “sought to navigate—and, in some readings, to narrow—the scope of the Places of Worship Act, 1991”, signalling that we are reporting a pattern discernible in their litigation strategies and public rhetoric, rather than ascribing a single, uncontested intention to them.

We hope these changes address your concern about “which Muslims?” and “which groups?” and make our empirical grounding and use of evidence more transparent.

comment 5: “Some feedback from the previous version relates to lack of detail about what data has been collected, the methodological approach used here, and the analytical framework. This newer version unfortunately does not adequately address these shortcomings.”

Response 5: We have substantially expanded and clarified the methodological discussion in three ways: (1) Explicit methodological section. The Methodology section now clearly states that the article combines doctrinal legal analysis (of Supreme Court, High Court, and trial-court decisions; statutory texts; and parliamentary debates on the PoW Act and the AMASR Act) with qualitative interpretation of public discourse, including media reports and public statements by litigants and religious organizations. (2) Specification of data sources. We now specify the types of primary legal materials used (judgments, orders, pleadings, petitions) and clarify that the three focal cases were selected through purposive sampling as high-salience disputes that: have generated substantial higher-court litigation since the Ayodhya judgment; directly or indirectly test the scope of the Places of Worship Act, 1991; exhibit discernible patterns of interaction between archaeological evidence, statutory interpretation, and political narratives. (3) Clarified analytical framework. As noted above, we now set out a tripartite analytical framework—treating places of worship as (i) indivisible sacred spaces, (ii) produced spaces, and (iii) mnemonic anchors—and explicitly state that this framework is used to read the case material, rather than merely citing these theories in a free-floating way. The case-analysis section then applies this framework to draw out patterns across the three disputes, including the reframing of claims, the use of ASI reports and archaeological evidence, the creation of new interim arrangements, and the institutional repositioning of the ASI and the courts.

We hope this responds to your request for greater clarity about what data, what method, and what framework guide the analysis. Once again, we thank you for your careful and constructive review. Your comments have helped us clarify the article’s contribution, tighten its structure, and strengthen its empirical and methodological foundations, and we believe the manuscript is significantly improved as a result.

Reviewer 2 Report

Comments and Suggestions for Authors

Check for places where the indentations are off and/or the sentence is cut off and a new paragraph is begun mid-way, see page 6 line 245-246

Author Response

Response to Reviewer 1 Comments (Round 2)

1. Summary

We thank you for the careful reading of the manuscript and the constructive comments.

Comment: “Check for places where the indentations are off and/or the sentence is cut off and a new paragraph is begun mid-way, see page 6 line 245-246”

Response: English language and clarity

We have undertaken a thorough language edit of the manuscript to improve clarity, fluency, and consistency in the use of terms. In particular, we have corrected awkward phrasing, standardized spelling and punctuation, and smoothed transitions between sections so that the main arguments and methodological choices are expressed more clearly.

Formatting and paragraphing issues (p. 6, lines 245-246)

We have carefully checked the entire manuscript for places where indentations were off or sentences were inadvertently cut off by mid-sentence paragraph breaks, including the instance noted on p. 6, lines 245-246. These have now been corrected so that paragraphs and sentence breaks follow the logical structure of the argument and do not interrupt the flow of the text.

We are grateful for these suggestions, which have helped us improve the readability and presentation of the article.

Reviewer 3 Report

Comments and Suggestions for Authors

Upon reading the second draft of “Litigating the Sacred: Legal, Memory, and Spatial Dynamics in Worship Conflicts in Contemporary India,” I can confirm that the authors have cleared up the issues identified in the initial version. The paper is now ready for publication. With that, I'll list a few more minor suggestions in line-by-line fashion.

33: There's an extra space after “weight”.

42-57: Too much of this paragraph is indented.

82: I'm thinking you should italicize “kar sevaks”.

110: The font changes for “evidence”.

138: Italicize “gopuram”.

143: Italicize “garbhagrha”. Perhaps give the entire paper one last look-through for non-English words to italicize.

158: Put the period after the citation.

213-224: Too much of this paragraph is indented.

245-246: Reconnect this as one paragraph.

247: Instead of just “Illustrative,” try starting this sentence with “It is illustrative that . . .”

TABLE: In the first entry in the Gyanvapi column, capitalize “seeks”. Also, I think “that have” should be changed to “each of which has”, as the sentence reads a little awkwardly at present. Also, italicize “wuzukhana” and “shivling”.

377: Standardize the number of spaces you are going to use before and after an em-dash. Here, you've got spaces before and after, but in lines 25 and 373, for example, you've got no spaces before and after the em-dash.

434-447: Too much of this paragraph is indented.

461-480: Too much of this paragraph is indented.

574: Instead of “lens on”, try “lens for examining.”

Author Response

Response to Reviewer 3 Comments (Round 2)

1. Summary

We are very grateful to Reviewer 3 for the generous and encouraging assessment of the revised manuscript, and for the careful, patient line-by-line guidance. Your conclusion that the paper is now ready for publication, together with your detailed suggestions on minor points, has been extremely motivating for us.

Response to Comments and Suggestions for Authors

Comment: Upon reading the second draft of “Litigating the Sacred: Legal, Memory, and Spatial Dynamics in Worship Conflicts in Contemporary India,” I can confirm that the authors have cleared up the issues identified in the initial version. The paper is now ready for publication. With that, I'll list a few more minor suggestions in line-by-line fashion.

33: There's an extra space after “weight”.

42-57: Too much of this paragraph is indented.

82: I'm thinking you should italicize “kar sevaks”.

110: The font changes for “evidence”.

138: Italicize “gopuram”.

143: Italicize “garbhagrha”. Perhaps give the entire paper one last look-through for non-English words to italicize.

158: Put the period after the citation.

213-224: Too much of this paragraph is indented.

245-246: Reconnect this as one paragraph.

247: Instead of just “Illustrative,” try starting this sentence with “It is illustrative that . . .”

434-447: Too much of this paragraph is indented.

461-480: Too much of this paragraph is indented.

574: Instead of “lens on”, try “lens for examining.”

Response: we have carefully implemented all of the specific line-level corrections you noted. In particular, we have: corrected extra spaces, font inconsistencies, and misplaced periods; standardized indentation and paragraph breaks in the sections you flagged; adjusted phrasing where suggested (for example, the sentence beginning “Illustrative …” and the phrase “lens on”); and applied consistent italics to non-English terms such as kar sevaks, gopuram, garbhagriha, wuzukhana, and shivling, including in the comparative table, along with the capitalization and wording changes you recommended there.

Some of the formatting issues you identified arose from our own carelessness and some from incompatibilities between different word-processing and conversion tools. In light of your comments, we not only corrected the specific instances you mentioned, but also undertook an additional, systematic check of the entire manuscript to ensure consistency in indentation, spacing (including around em dashes), typography, and the treatment of non-English terms.

We sincerely appreciate the time and attention you devoted to these fine-grained suggestions, which have significantly improved the readability and presentation of the article.