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Supreme Court Upholds Dismissal of Christian Army Officer Over Refusal to Enter Temple and Gurdwara

The court held that military discipline prevails over non-essential religious claims under Articles 25 and 33.

Overview

  • A bench of Chief Justice Surya Kant and Justice Joymalya Bagchi dismissed Lt. Samuel Kamalesan’s plea, terming his conduct “the grossest kind of indiscipline” and declaring him a “misfit” for the Army.
  • The officer, commissioned in 2017 with the 3rd Cavalry Regiment, refused to enter the sanctum at the regiment’s temple and gurdwara during weekly parades, citing his Protestant Christian beliefs.
  • The judges noted he ignored counselling, including a pastor’s advice that entry would not violate Christian tenets, and emphasized that commanders must lead by example.
  • Relying on Article 25’s focus on essential religious practices and Article 33’s allowance for curtailing rights to preserve force discipline, the court prioritized unit cohesion and morale.
  • Affirming a 2021 dismissal already upheld by the Delhi High Court in May, the Supreme Court also declined to reduce the penalty on proportionality grounds.