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Sati is known to be a custom of widow burning in Hindu society. Although it sometimes leads the actor to be deified and worshiped as satimata, satimata worship is presently prohibited by the Commission of Sati (Prevention) Act implemented in 1988. Focusing on an example of satimata worship and the management of a sati temple in Rajasthan, this paper analyses state regulation of the Rani Sati temple and the public confrontation between the state and the temple managers. It shows that the temple managers have clearly attempted continuous negotiation, no matter how subtle, against the state through the use of legal institutions and court appeals. Analysing the historiography of the temple management leads us to comprehend how religion can actually transform under the impact of state intervention. 1. Introduction 1-1. The state – religion interaction in contemporary India This paper1 aims to analyse the distinctive interaction between the state and religion in contemporary India, especially by using a case study of the Hindu custom of satimata worship. Sati is known to be a custom of widow burning in Hindu society. It sometimes leads the actor to be deified and worshiped as satimata. Numerous examples of this deification and worship can be observed, especially in Rajasthan [Noble and Sankyan 1994]. Satimata worship, or legally speaking, the ‘glorification of sati’, is presently prohibited by the Commission of Sati (Prevention) Act implemented in 1988. Focusing on an example of satimata worship and the management of a sati temple in Rajasthan, * The original version of this paper was read at the MINDAS workshop (National Museum of Ethnology) held on 11 Oct. 2014, and at the FINDAS workshop (Tokyo University of Foreign Studies) on 10 Jan. 2015. ** Associate Fellow at International Research Center for Intangible Cultural Heritage in the Asia-Pacific Region under the auspices of UNESCO, Osaka, Japan. 1 this paper analyses state regulation of the Rani Sati temple and the public confrontation between the state and the temple managers, leading to a better understanding of the ongoing transformation of the religious practice of satimata worship under state regulation. The relationship between the state and religion in India is said to be unique in terms of the characteristics of the ‘secular’ regime, which officially places religion not in the private but in the public domain. Gurpreet Mahajan agrees that ‘the state was to have no religion of its own, but religion was not also viewed as personal or private matter: it was places squarely in the public domain and the state was expected to be involved in a variety of ways with religion’ [Mahajan 2008: 301-302]. Because of the ‘public’ nature of religion, it is inevitably affected by the state’s influence and its secular institutions and ideas that ensure ‘equality’ for all Indian citizens and religious denominations. It is clearly noticeable in Article 25 (1) of the Constitution of India, which guarantees the right ‘freely to profess, practice and propagate religion’ but is ‘subject to public order, morality and health’2. Borrowing the categorization of salient principles articulated in the Constitution of India by Rajeev Dhavan, we are able to acknowledge the following three components of Indian secularism: ‘religious freedom’, ‘celebratory neutrality’ and a ‘regulatory and reformative justice’ [Dhavan 2001: 311]. Religious freedom entails not only the right to religious thought and practice but freedom from discrimination based on religion, caste, gender, etc. The second principle is to encourage a participatory state neutrally assisting and celebrating all faiths and generally not discriminating among them. As the third salient feature, the Indian secular state takes on the important role of emphasizing regulatory and reformative justice. The Constitution allows the state to conduct ‘social welfare and reform’ and, particularly, to abolish ‘social evils’ like untouchability. In order to secure equality and justice for the Indian citizens, the state sometimes curtails religious freedom on the grounds of ‘public order, health and morality’ and regulates the ‘economic, financial, political or other secular activity’ of a religion. To make it feasible for the state to achieve regulatory and reformative justice with regard to religion, the Indian legal system also acts as a link between the secular public order and religion. As Marc Galanter discloses, the Indian judiciary especially engages in an ‘overall arbitral role’ between the state and religion pursuing a delicate combination of religious freedom as well as a mandate for active state promotion of the transformation of religion [Galanter 1993: 250]. In the case of the transformation of Hinduism under the secular government’s auspices, the Supreme Court interestingly acts as the vanguard of religious reform by judging Hinduism by an ‘essential practices test’ that decides which part can be constituted as essential and integral. Ronojoy Sen interprets that the Supreme Court has two distinctive roles in order to rationalize religion and marginalize practices that would not meet the test, first as the ‘gatekeeper as to what qualified as religion’ and 2 FINDAS ࣜࢧ࣮ࢳ࣮࣌ࣃ࣮ 4 second in ‘the role of shifting superstition from “real” religion’ [Sen 2010: 55]. Our case study of the Rani Sati temple can be considered to constitute a part of the series of literatures that disclose the unique relationship between the state and religion. However, these deal more with the reformative and regulatory role of the state in Hinduism, but focus less on the actual reaction or response from religious agencies on which the state regulation is hugely imposed. My paper therefore focuses on the close interaction between the state and religion and on the actual process of transformation of religious practices by state regulation. My research on the state intervention in the management of the Rani Sati temple shows that the temple managers have clearly attempted continuous negotiation, no matter how subtle, against the state through the use of legal institutions and court appeals. Analysing the historiography of the temple management leads us to comprehend how religion can actually transform under the impact of state intervention. 1-2. Satimata worship and the Rani Sati temple Historically speaking, sati, i.e., widow immolation, has always been controversial in the Hindu tradition [Thapar 1988]. While some medieval Sanskrit texts give religious sanction to widow immolation as an ideal endeavour on the part of Hindu widows, others demand its abolition [Kane 1974: 624-636]. It was made illegal in 1829 during the British colonization of India. After Indian attained independence, the newly formed government banned sati through the Indian Penal Code (1860), but the custom has not been entirely eradicated and is known to sporadically occur3. The most (in)famous sati incident, causing nationwide controversy in India, occurred on 4 September 1987, in Rajasthan. An eighteen-year-old Rajput woman, Roop Kanwar, allegedly immolated herself on the funeral pyre of her husband at Deorala (Sikar District). The case enraged many feminist organizations and coalesced into the anti-sati movement, in opposition to the pro-sati movement by Hindu nationalists who glorified Roop Kanwar [Hawley 1994]. In accordance with requests from the anti-sati organizations, the then government led by Rajiv Gandhi implemented an independent anti-sati act named the Commission of Sati (Prevention) Act in 1988 (henceforth referred to as the Act). It not only prohibits the act of widow burnings, but also the glorification of sati, i.e., the worship of satimatas. Satimata worship is conspicuously observable in Rajasthan, as Lindsey Harlan found while examining the cultural significance of gender roles within the context of satimata worship by Rajput women in Mewar. She explains how only a Rajput woman who can selflessly sacrifice herself with complete devotion to her husband can become a satimata