A pattern of litigation is now running across at least six contested religious sites in three states. It is doing to the Places of Worship (Special Provisions) Act, 1991, what neither parliament nor the Supreme Court has been willing to do. The Act is not being amended. It is not being struck down. It is being made unavailable to those it was written to protect, one site at a time, through a different doctrinal route each time.The Bhojshala verdict delivered on Friday (May 15) by the Indore Bench of the Madhya Pradesh high court is the latest expression of this pattern. It is also the most ambitious. The Bench comprised Justices Vijay Kumar Shukla and Alok Awasthi. It has held the 1991 Act inapplicable to Bhojshala. The ground is that the site is a centrally protected monument under a different statute. The route the Bench has used was not, until now, available. The verdict adds a sixth procedural pathway to a map that already had five.As the Hindustan Times has reported, litigation similar to Bhojshala is now alive in courts from Uttar Pradesh through Karnataka. The geographic spread is itself the analytical fact. What follows is the spread, read against the Act it is dismantling.The Act and the wagerThe 1991 Act was parliament’s reply to the demolition cycle of the late 1980s. Under it, the religious character of every place of worship in the country was frozen as of August 15, 1947. Any change in that character was prohibited. The Ayodhya Bench of 2019 treated the Act as a basic feature of the secular constitutional order, immune to ordinary legislative revision. The wager was simple. The past would be set beyond the reach of judicial inquiry. Civil peace in the present was the price exchanged for that quiet.That wager is no longer being honoured. The six sites that follow show why.Uttar PradeshAt Varanasi, the route opened in 2021. In August that year, five Hindu women filed a suit at a civil court. They sought permission to worship at the Maa Shringar Gauri site within the Gyanvapi mosque complex. A civil court ordered a video survey of the complex in May 2022. The Allahabad high court has since held that the 1991 Act does not bar the suit. The doctrinal route opened at Gyanvapi is the procedural one. The 1991 Act, the courts hold, only bars conversion. It does not bar a suit that seeks to ascertain what the site’s religious character was on August 15, 1947. Order a survey. Read its findings. Then decide.At Mathura, the route is litigation by mass. The Allahabad high court is hearing 18 suits over the 13.37-acre Katra Keshav Dev site. The plaintiffs seek possession of the land and the removal of the Shahi Idgah Mosque. Sixteen of the suits were transferred from Mathura courts to the high court in June 2023. In August 2024, the high court held them maintainable. The Muslim side’s invocation of the 1991 Act was set aside at the threshold. The route here is to put the Act in tension with itself. One suit dismissed leaves 17 pending. The Act becomes a question of triage, not of finality.At Sambhal, the route is speed. On November 19, 2024, a civil judge in Chandausi admitted a suit by eight Hindu petitioners. The same judge ordered a survey of the Shahi Jama Masjid the same day. The first survey was conducted within hours. On November 24, a second survey ended in police firing. Five Muslim men were killed. The Act’s bar on conversion presupposes a court that examines the bar before acting. A same-day survey order leaves no space for that examination. By the time the bar is considered, the survey has been conducted and the political record altered.Madhya PradeshBhojshala adds a sixth route. It is doctrinally distinct from all the others, because it does not work around the 1991 Act. It holds the Act inapplicable in the first place.The Indore Bench has reasoned as follows. Bhojshala falls within the carve-out in the 1991 Act for monuments protected under the Ancient Monuments and Archaeological Sites and Remains Act, 1958. Centrally protected status has applied to the Bhojshala monument since 1904. The carve-out was conceived as a technical measure. Its purpose was to keep conservation law operative on protected monuments. It was not designed as a parallel jurisdiction for redetermining religious character. The Indore Bench has converted it into one.Having held the 1991 Act away, the Bench then invoked Section 16 of the 1958 Act. The section’s text directs that a protected place of worship may not be put to a use that conflicts with its character. The Bench identified the character of Bhojshala as that of a temple. It rested its identification on historical scholarship, the architecture of the structure, and the ASI’s 2024 scientific survey. The 2003 ASI order permitting Friday namaz was quashed. The Muslim community of Dhar has been told to approach the state government for land at a different location in the district. If it wishes to build a mosque, it must build there.India has more than 3,500 centrally protected monuments. A much larger number sit under state protection. All of them are now within reach of the Bhojshala route.KarnatakaAt Malali, near Mangaluru, the Hindutva right has discovered a more elegant route. In April and May 2022, repair work at the Assayed Abdullahi Madani Mosque required the demolition of an old wall, which exposed carved stonework. Litigation followed. In November 2022, a civil court held the Hindu petitioners’ suit maintainable. The mosque’s invocation of Section 4 of the 1991 Act was rejected. The route here is the conversion of renovation into evidence. The mosque becomes evidentiarily unstable in the act of its own repair.At Hubballi, the route is to recharacterise the site as non-religious. The Idgah Maidan there is owned by the municipality. It is held by Anjuman-e-Islam under a 999-year lease at one rupee a year, dating from 1921. In August 2022, the Hubballi-Dharwad Municipal Corporation permitted Ganesh Chaturthi celebrations on the ground. Anjuman-e-Islam approached the Karnataka high court. The court found the land to be a public ground. The Muslim party’s religious use of the site, the court held, was too intermittent to qualify it for the 1991 Act’s protection. The Act’s shield, on this reading, is available only to those whose religious occupation has been continuous, exclusive, and provable to a court.The Supreme Court’s correctiveThere was a moment when the apex court appeared to recognise the pattern. The Sambhal deaths prompted a corrective measure. On December 12, 2024, the Supreme Court issued an interim order. It barred fresh suits and prohibited effective or final orders in pending ones. The order was issued in the batch of petitions led by Ashwini Kumar Upadhyay v Union of India. The petition challenges the 1991 Act’s constitutional validity itself. It has been pending in the Supreme Court since 2020.The corrective measure has not held. The Indore Bench has held the December order inapplicable to the Bhojshala matter on two grounds. The first ground is temporal. The Hindu Front for Justice petition was instituted in 2022. That was ahead of the December 2024 restraint. The Bench has taken the view that the restraint cannot reach back. The second ground is the Supreme Court’s own conduct. On January 22 of this year, the apex court returned the dispute to the Indore Bench. The proceedings on that date were ones in which the apex court’s own December 2024 order would have been known to its members. Whether these grounds will survive appellate scrutiny is now a question the Supreme Court will need to answer.Even before this verdict, the corrective was hollow at the centre. The mere pendency of the Upadhyay petition, in the absence of a merits decision, has sent a clear institutional signal. The 1991 Act is contestable. Its protections are not final. The lower courts venturing into religious-character adjudication have been reading that signal accurately.What the pattern showsRead across the three states, the doctrinal vocabularies differ. The destinations converge. Survey at Gyanvapi. Volume at Mathura. Speed at Sambhal. Renovation at Malali. Recharacterisation at Hubballi. Antiquarian exemption at Bhojshala. Each is a different route. None is being defended at the apex by the Supreme Court.The geographic spread matters because it shows that the pattern is not a UP phenomenon, not a BJP-state phenomenon, not a north-Indian phenomenon. It runs from Varanasi through Dhar into Mangaluru and Hubballi. The doctrinal variety matters because it shows that the pattern is not the product of a single legal theory. It is the product of a permissive institutional environment in which six different theories have produced the same outcome.There is, in this context, an old caution the Indore Bench has elected to forget. The five judges who decided Ayodhya in 2019 had taken pains to fence in their own verdict. That verdict, they wrote, was an answer to a single dispute. It was not a method to be lifted out and applied across the country. The 1991 Act, the same judgment said, was there for a reason. It ensured that no other site would be reopened in the manner that Ayodhya had to be. The Indore Bench has drawn on Ayodhya’s evidentiary methodology but has stayed silent on this fencing. The silence is itself a holding. The fence has been quietly dismantled.Two questions now sit before the apex court. The first is whether the model offered at Indore should be corrected, or whether it should be normalised. The second is the larger one. It is not whether the 1991 Act survives on paper. It will. It is whether the Act will remain available, in practice, to the communities it was passed to protect.