Since the forcible destruction of the Ayodhya temple in north India in 1992, the issue of rights to worship in contested holy places in India has been a major focus of attention.  The High Court judgment in September 2010 has intensified the controversy.  Its recognition of the Lord Rama as a juridical personality, and of the site itself as a deity whose worship establishes legal rights, flies in the face of the secularist principles of the Indian constitution.   This modern history is compared with struggles over rights to worship at sacred places in eighteenth century India, in the hope of adding to our understanding of some of the religious and juridical principles out of which modern positions have emerged.