ABSTRACT
The Indian Constitution recognizes sex equality yet confers jurisdiction over civil matters such as marriage and divorce to religious “personal laws,” which make no similar guarantee. In the United States, courts have created a “ministerial exception” granting religious institutions an exemption from Title VII of the Civil Rights Act of 1964, which prohibits sex discrimination in the workplace. More than 180 countries are signatories to the international Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW) of 1979—often referred to as the “international bill of rights for women”—and yet ratifying countries have conditioned their ascent to instances where there is no conflict between CEDAW and religious law.
