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Interpretation Of Secularism In The Context Of Indian Constitution

Secularism is an English philosophy developed during time of Enlighten Movement in Europe. It was first coined by George Jacob Holyoake in 1851. To him Secularism is a social order separate from religion without criticizing the beliefs of religion. Secularism is an aggravated and ambiguous doctrine everywhere. This secularism is contested even by academics due to its varying ambit and proximity of differentiation in religion and state in top nation sates. Indian academics were among the first to voice their opposition to Secularism[1].

The Indian model of Secularism is a different and much molded version which tend to suit in the society with diverse socio cultural and religious diversity. Indian State recognizes all religion but has no religion. The political system and government mechanism of India is free from religious influence.

The word "Secularism" is used only in the Preamble of Constitution, where the word "secular" was inserted by the 42nd Amendment 1976. But its essence was impliedly enshrined in the Constitution in Article 14, 15, 16, 19, 21, 25-29 and 44 where a deep dive into these provisions of the Constitution reflects that this concept is limited, qualifies and unique. The change was enacted during the tenure of Prime Minister Indira Gandhi during the period of Emergency.

Secularism in India recognizes the right of religious organizations to create and sustain educational institutions in addition to the freedom of individuals to follow their own religious convictions. Indian secularism does not establish a rigid division between the state and religion, in contrast to many other versions. Rather, it recognizes Indian society's diversity and plurality of religions.

It is focused on the relationships and impacts between various religions in addition to problems within specific faiths. With this concept, the state is able to interact with faiths without trying to suppress or control them. The state does not support any one religion, but it does formally recognize and give public recognition to religious communities.

Keeping a moral distance and striking a balance between various values are key components of the Indian approach to secularism. This indicates that the state makes an effort to balance many, occasionally unclear, but equally significant values. It is a democratically negotiated, contextual, ethically sensitive, and flexible agreement rather than a strict, one-size-fits-all ideology.

In India, secularism seeks to guarantee each person's complete enjoyment of life, liberty, and happiness. But in their interactions with other people, secularists need to approach this objective with a sense of moral purpose. It's about creating an environment in which individuals from different religious backgrounds can prosper and live side by side.

The Hon'ble Supreme Court in the case of Ahmadabad St Xavier's College Society V State of Gujarat[2] described the religious, linguistic and cultural diversity of India in the following legendary words: "India is the most popular country of the word. The people inhabiting this vast profess different religious and speak different language. Despite the diversity of religion and language, there runs through the fabric of the Nation the golden thread of a basic innate unity. It is a mosaic of different religious, languages and cultures. Each of them has made a mark on the Indian policy and India today represents a synthesis of them all."

This project does not encompass the political and philosophical ideology of Secularism but deals with 'Secularism' in Indian Constitution, its development through various precedents and its interpretation at times of issues with religious institutions and the object of the State.

Meaning Of Secularism
Secularism can also refer to a similar stance that aims to eliminate or reduce the influence of religion in any public domain. Secularism is most frequently understood to be the separation of religion from civil affairs and the state. Secularism in liberal context means the complete separation of religion from the politics.

In Transformationalist ideology religion should be treated as a private matter and it tends to create scientific perspectives among the individuals. However, it is a system of doctrine and practice that disregards or rejects any form of religious faith and worship[3]. Secularism in Indian context means the religious neutrality of the State and religious tolerance among individuals of various theological groups.

Constitutional History Of Secularism
The concept of secularism as embodied in the Constitution of India is not similar to western view about secularism. The provisions of religious freedom were put forth by framers of the constitution only after great debates which aims is nondiscrimination of religious groups. Many years ago, when India's Constitution was being drafted, B.R. Ambedkar, who piloted various drafts through the Constituent Assembly, stated that the individual rather than the group was the basis of the Indian Constitution[4].

The Constituent Assembly's vacillation between strict separation, Hindu majoritarianism, and various intermediate alternatives is widely held to have settled on the notions of Sarva Dharma Sambhava (good will toward all faiths) and Dharma Nirpekshata (religious neutrality), to which duo, a third, the Gandhian Vasudeva Kudumbakam (universal brotherhood), is frequently added. Nevertheless, such formulations greatly understate-and to some extent, misstate-the importance accorded to religion by the Constitution.[5]

Professor KT Shah interjected on November 15, 1948, during a contentious debate about the character of the Constitution in the Constituent Assembly, during which the newly independent Indian government was taking place. He demanded that the word "secular" be added to the Preamble of the Constitution. "Sir, I implore you to include the words 'Secular, Federal, Socialist' after the term 'A' in Clause (1) of Article 1. "India shall be a secular, federal, socialist Union of States," he declared, rewording the article or phrase. Following the debate, members agreed that the Indian government should follow secular ideals, leading to the word "secular" being removed from the preamble.

Secularism was strongly supported by the majority of the founders of modern India, who were influenced by European concepts and customs. Jawaharlal Nehru, the nation's first prime minister, was foremost among them. He considered the existence of a secular state to be a crucial component of modernity. During the deliberations in the Constituent Assembly, he stated, "We have done the same thing as every country except the advanced countries, the backward countries."

Contrary to popular belief, Nehru and Dr. B R Ambedkar, the Chairman of the Constitution Drafting Committee were adamantly against the concept of putting the word "secularism" in the preamble of the Constitution.

According to academics like Ashish Nandy and T.N. Madan, India's secular state was destined to fail. According to Madan, given the current situation, "secularism in South Asia as a generally shared credo of life is impossible, as a basis for state action impracticable, and as a blueprint for the foreseeable future impotent"[6].

When the Preamble of the Constitution was debated in the Constituent Assembly, the debate on incorporating secularism took up much time. Political scientist Shebali Jha explains in an article, "All members agreed on the need to establish a secular state. Most shared an understanding of history. In it the move to separate religion and state was irrevocably part of a plan to democratize the latter. The link between secularism and the effective functioning of democracy is well established in Europe. Secularism was considered absolutely necessary as India was to follow the principles of democracy"[7].

Ambedkar and Nehru were devoted to the secularist ideal. Whether one is Christian, Sikh, Muslim, or Hindu, this is an ideal for all of us. Nehru remarked, "No matter who we are, none of us can firmly state that he has no prejudice or communalism in mind or heart".

"What should be the policy of the state, how society should be organized socially and economically are matters for the people to decide according to time and circumstances"[8], stated Ambedkar in a clarification of his views on the state after secularism. It totally undermines democracy; hence the Constitution cannot contain it.

In order to further advance secularism, the Constituent Assembly subsequently approved Articles 25, 26, and 27 of the Constitution. Secularism is deeply ingrained in the constitutional ideology, even if it is not expressly stated in the document. They knew that secularism in the proper sense of the word could not be applied in the Indian context and that it had to be interpreted where it emerged. It is in the words of Ian Copeland, "It is better not to use the word than to use it fraudulently".

It was then by the 42nd Amendment Act, the then Prime Minister Indira Gandhi added the word "Secular" in the preamble of Indian Constitution.

Secularism: A Part Of Basic Structure
India gained independence from British colonial rule in 1947. They now set out to make a new, challenging attempt to establish an economically independent democracy that would provide for the rights of all of its citizens. India was dedicated to the idea of secularism in its place. With Pakistan's independence from India on religious grounds, the idea of secularism has gained greater significance. India had held the belief during the division that it wished to create a country in which its people would not have a religious identity.

The term 'secular' was inserted into the Preamble of the Indian Constitution by the 42nd Constitutional Amendment (1976), notwithstanding the Constituent Assembly's reluctance to include it in the original text. It shows that India is a union of states that is apart from religion and that it will protect religious freedom for followers of all faiths without targeting any individual due to their religion.

Articles 25 to 28 of the Indian Constitution grant everyone the ability to practice their religion freely, both individually and collectively, under the heading of the Fundamental Rights guaranteed by Part III. Articles 15 and 16 of the Indian Constitution also guarantee nondiscrimination based on religion. Thus, it can be said that through its Preamble, Fundamental rights and Directive Principles of State Policies, India have developed themselves into secular state grounded on the belief of impartiality, justice and fairly[9].

With the advent of the Indian Constitutional ideology of social and economic democracy, secularism has come to be seen as one of the fundamental components of the Indian Constitution. This means that the fundamental framework of secularism cannot be removed from constitutional legislation by the parliament using the amendment authority granted to it by Article 368 of the Constitution. It is claimed that belief is the subject of religion. Even if some may disagree, it is undeniably true that India and its people have embraced globalization, yet at their core, they continue to adhere to deeply held religious beliefs. Undoubtedly, the way that "secularism" is currently viewed in India is worrying.

The idea of secularism has occasionally been developed by the Indian Supreme Court. For example, the Hon'ble Supreme Court addresses the idea of secularism for the first time in the case of Sardar Taheruddin Syedna Saheb v. State of Bombay[10]. During the discussion of the secular nature of the Indian Constitution, Ld. J Ayyangar of the Hon'ble Supreme Court clarified that Articles 25 and 26 of the Indian Constitution incorporate the traditional understanding of secularism, which includes the idea of religious toleration. Again, in the case of the Keshwananda Bharti v. The State of Kerala[11], the Court held that Secularism is the basic structure of the Constitution. Highlighting the nature of the Constitution J Sikri ruled that Constitution is Secular in its character.

The Essence Of Secularism In Indian Constitution
The concept of secularism as embodied in the constitution of India is neither anti-religious nor irreligious. The state neither practices any religion nor does it decry any religion. It respects all religion and faith, but it keeps religion and politics separate[12]. When it comes to providing benefits to residents of all faiths and creeds, the state is impartial and nondiscriminatory. It emphasizes reason, integration, and peace within the political community in place of religion, caste, community, culture, creed, language, or regional differences that arouse emotions.
  • Article 14 grants equality before the law and equal protection of the laws to all.
  • Article 15 enlarges the concept of secularism to the widest possible extent by prohibiting discrimination on grounds of religion, race, caste, sex or place of birth.
  • Article 16 (1) guarantees equality of opportunity to all citizens in matters of public employment and reiterates that there would be no discrimination on the basis of religion, race, caste, sex, descent, place of birth and residence.
  • Article 25 provides 'Freedom of Conscience', that is, all persons are equally entitled to freedom of conscience and the right to freely profess, practise and propagate religion.
  • Article 26, every religious group or individual has the right to establish and maintain institutions for religious and charitable purposes and to manage its own affairs in matters of religion.
  • Article 27, the state shall not compel any citizen to pay any taxes for the promotion or maintenance of any particular religion or religious institution.
  • Article 28 allows educational institutions maintained by different religious groups to impart religious instruction.
  • Article 29 and Article 30 provides cultural and educational rights to the minorities.
  • Article 51A, states Fundamental Duties obliges all the citizens to promote harmony and the spirit of common brotherhood and to value and preserve the rich heritage of our composite culture.
The Indian Constitution takes into consideration that all religions, including atheism, are treated equally under the law and that no religion defines the state. Promoting harmony between individuals of many religious beliefs while upholding the principle of equitable treatment for everyone is the constitutional responsibility of both the state and its citizens. The constitution provides freedom of conscience, freedom to profess, practice, and propagate religion, as well as freedom to create religious institutions and to govern and administer their affairs. It also ensures equality and equal protection under the law.

Every Indian has the right to equal access to political and economic opportunities in the State, even while their freedom to practice, profess, and propagate their religion is subject to restrictions for grounds of public order, morality and health. All citizens are entitled to the same fundamental rights and are subject to the same fundamental duties and obligations, regardless of their faith. Thus, the tenets of Indian secularism include equality, freedom for all, and mutual respect for one another's faith.

The Scope Of Interpretation Of 'Secularism'
The Doctrine of Essential Practices:
The Hon'ble Supreme Court established the Doctrine of essentiality as a body of jurisprudence, or a legal principle, through a number of court precedents. The rituals and customs that are significant and required for a given religion and that adherents to it must follow are known as essential religious practices.

The doctrine was formulated by the 7-judge bench of the Supreme Court in the case of the Commissioner, Hindu Religious Endowments, Madras v. Shri Lakshmindra Thirtha Swamiyar of Shri Shirur Mutt[13], famously known as the Shri Shirur Mutt Case, 1954. It was decided that rituals essential to a specific religion shall be included within the term "religion." The Constitution's Article 25(2) grants the state the authority to enact laws governing the political, economic, and other aspects of religiously-related activity.

Nonetheless, the courts were given the authority to decide what falls under the purview of essential religious rituals. It would not have been sufficient to just mention the two separate domains of law and religion in light of India's diversified democratic framework, which has flourished on the solid foundation of both laws and rights. It is also true that, despite their obvious differences, law and religion serve as the foundation for societal demands.

Therefore, in creating and granting protection to such ideas that are important to the existence of the religion, the Apex Court and the High Courts have established some guidelines that can be used as a standard. The writers conduct a thorough study in the parts that follow to determine how important religious practices are treated by both personal and constitutional law.

"Freedom of conscience and right to freely practice, profess, and propagate religion subject to public order, morality, and health"[14] are guaranteed by the Constitution. The word "person" was used to express the framers' deliberate attempt to grant religious freedom to every person, regardless of whether or not they were citizens of the nation. Furthermore, the Constitution aimed to strike a balance between the rights to practice one's religion and the advancement of society, which was expressed in the requirements of appropriate constraints indicated in each of these rights.

But considering the vast number of beliefs found in all religions, granting legal protection to any belief-even one that had nothing to do with a particular religion-would have resulted in an almost daily barrage of religious claims from every community in the courts. Thus, only those religious practices that come under the wide category of fundamental religious practices were granted protection under Articles 25�28. The responsibility of determining the nature of the practice in question has now fallen on the courts.

Thus, "it is for the Court to ascertain whether a practice forms an essential part of the religion", the Honorable Supreme Court of India has said. The Supreme Court considers these issues in the context of that particular religion's beliefs when they come up for consideration. The following are the main criteria that have been taken into consideration when determining whether a practice is necessary, even if they have not been explicitly established by the courts.
  1. Test of Scriptures
    Scriptures, sometimes called the holy or sacred text, are works of literature pertaining to a specific religion. The scriptures of the majority of faiths not only help individuals develop a religious identity and sense of spirituality, but they also lay out the key ideas that lead a particular religion's adherents. In order to demonstrate impartiality and deference to both religion and the law, courts frequently consider religious texts and doctrine when determining the necessity of a particular activity. Thus, evaluating religious behaviors via the prism of scriptural evidence is crucial to determining which practices are fundamental. As a result, it is now standard procedure for courts to decide these types of cases based on the evidence presented or in front of the Court of Law.

    Hon'ble Mr. Justice Kurian Joseph's position in the historic Shayara Bano vs. Union of India[15] addressed this issue by confirming and making it clear that relying just on the knowledge of individuals claiming to be the "keepers of religion" was insufficient in matters pertaining to religion. Therefore, it is required by the constitution that these ideas be given serious consideration after being thoroughly examined and not just based on community assertions. Therefore, whether a behavior is mentioned explicitly or implicitly in religious scriptures and doctrines is one of the crucial aspects that must be taken into account when determining which acts are necessary.
  2. Test of fundamental change in religion
    There is a specific "body of doctrines and beliefs that are regarded by those who profess religion as being conducive to their spiritual well-being" inside every religion. From the perspective of such a religion, certain of these tenets and beliefs are essential. Therefore, from the perspective of the religion, essentiality is merely one of the factors that must be considered when determining if a religious practice is essential. Consequently, the importance can be assessed by comprehending how each of these activities has affected the essence of the religion. Therefore, it will be seen as an integral or important component of the religion if its removal has a direct impact on the religion's core principles.
  3. Test of genuineness of beliefs
    Courts have also placed emphasis on evaluating the importance of religious rituals and what their adherents connect with them on a number of instances. "Whether the claimed belief is 'genuinely' and 'conscientiously' held to be a part of the profession or practice of any particular religion" is the key question, according to Justice Mukherjea, rather than whether a particular religious belief or practice appeals to our reason or sentiment.

    If it can be determined that the professed belief has been sincerely and diligently preached by the adherents of the faith, then the practice can be considered an integral aspect of the faith. Therefore, the Supreme Court determined that these activities were fundamental to their religion when determining whether or not these professed views were true. Therefore, when determining the integrality and essentiality of such ideas, the test of sincerity should also be taken into consideration.
  4. Test of nature of practice
    In assessing whether a practice is necessary, it is also critical to evaluate its character in order to classify the activity as requirements or preferences. In Acharya Jagdishwaranand Avadhuta and Ors. v. Commissioner of Police[16], for instance, the Supreme Court ruled that the petitioners' religion did require them to perform the "Tandava Dance" in public, hence the dance was an integral or essential part of their faith, and declared that the Ananda Margis have a right to perform 'tandava'.

    In the case of Church of God (full gospel) in India v. KKR Majestic Colony Welfare Association[17], it was held that:
    "No religion prescribes that prayers should be performed by disturbing the peace of others nor does it preach that they should be through voice-amplifiers or beating of drums. In any case if there is such practice, it should not adversely affect the rights of others including that of being not disturbed in their activities. And hence, usage of loudspeakers in the nature of practice cannot be considered an essential practice.
It is also to be noted that in the case of Acharya Jagdishwaranand Avadhuta and Ors. v. Commissioner of Police[18], the court held that the question of 'Whether absence of any such practices does any harm or alters the religion?' is primary essential in deciding if a particular practice is essential or not.

The Principle of Anti-exclusion:
The anti-exclusion principle proposes that principles of freedom of religion will not protect a practice if that practice impairs the dignity of an individual or hampers an individual's access to a basic good[19]. The anti-exclusion principle states that in order to protect religious groups' integrity, the State and the Court must consider the internal viewpoint of followers when determining the form and content of religious practices, unless those practices result in an individual's exclusion from economic, social, or cultural life in a way that diminishes their dignity or makes it more difficult for them to obtain necessities of life.

The Supreme Leader of the Dawoodi Bohra community, the Dai-ul-Mutlaq, challenged the Bombay Prevention of Excommunication Act, 1949 in Sardar Syedna Taher Saifuddin vs. The State of Bombay[20]. It was against the law for religious communities to kick someone out of their group. In addition to acting as a trustee for the community's assets, the petitioner asserted that he had the authority to banish any member of the group from the denomination. He thought that the Dawoodi Bohras' collective right to religious freedom depended on this authority.

The law was ruled unlawful by the court, with Chief Justice of India B.P. Sinha dissenting. It maintained that the Dai's authority to ban people from the group was so fundamental to their faith that laws aimed at social welfare could not be permitted to eradicate a religion. By referencing CJI Sinha's dissenting opinion in the Saifuddin case and situating it within the Indian Constitution's comprehensive transformative character, the anti-exclusion principle serves as a substitute for the "essential practices test."

This approach will obviously not apply to the first group of circumstances involving State control over property owned by religious institutions, which will still be subject to the constitutional text's religious/secular dichotomy. Nonetheless, it will be applicable in situations where disputes arise within religious communities and where constitutional protection for religious customs or practices is desired.

There was a clear conflict between two asserted rights in situations such as the ones involving the entrance to the Haji Ali[21] and Sabarimala shrines[22]: women's constitutional right to worship under Article 25(1) and the religious denomination's right to run its own business under Article 26(b).

Under such circumstances, the stronger individual right under Article 25(1) will supersede the denomination's claim, which is based on the exclusion and treatment of women as second-class members of the community. Applying the same, the section 3(b) of Kerala Hindu Places of worship (Administration of Entry) Rules, 1965 was held void[23].

Important Judicial Pronouncements:
In S.R.Bommai vs Union of India[24], it was held that, "Secularism is one of the basic features of the Constitution. While freedom of religion is guaranteed to all persons in India, from the point of view of the State, the religion, faith, or belief of a person is immaterial. To the State, all are equal and are entitled to be treated equally. In matters of State, religion has no place.

No political party can simultaneously be a religious party. Politics and religion cannot be mixed. Any State Government which pursues unsecular policies or unsecular course of action acts contrary to the constitutional mandate and renders itself amenable to action under Article 356".

In Aruna Roy v. Union of Indian Constitution[25] contemplates that the atheist is equally tied by any religion but every religious faith including an atheist is equally treated under the laws. It is a constitutional duty of the State and its citizens to foster harmony amongst the people of different faiths with the foresight of treating all persons India' the Supreme Court held 'secularism has a positive meaning, that is, developing, understanding and respect towards different religions.

In M. Nagraj v. Union of India[26] the Constitution Bench further said, "Secularism" is the principle which is the overarching principle of several rights and values under the Indian Constitution. Axioms like secularism, democracy, reasonableness; social justice, etc. are overarching principles, which provide linking factor for principle of fundamental rights like Articles 14, 19 and 21. These principles are beyond the amending power of Parliament. They pervade all enacted laws, and they stand at the principle of the hierarchy of constitutional values.

Bijoe Emmanuel v. State of Kerala[27], it was held that "Article 25 is an article of faith in the Constitution., incorporated in recognition of the principle that the real test of democracy is the ability of even an insignificant minority to find its identity under the country's Constitution. This has to be borne in mind in interpreting Article 25".

Scientific approaches to secularism and the promotion of social justice and equality in the material world require deliberate and planned efforts. It is undeniable that the Constitution guarantees the right to freedom of religion. We need to be aware of the circumstances in which someone's right to practice their faith is denied. The vast majority of people in India are religious. Many people think that there is humanitarian instruction in every scripture.

We should ascertain whether all religions are autonomous, tolerant, and able to include the complimentary elements of modernity into the educational curriculum. By doing this, everyone can respect various religions, and the freedom of faith can be consciously upheld. Individuals can acknowledge or reject religion. This will not bring about religious harmony or prevent isolation, alienation, or polarization.

The viewpoint of science is a crucial component of secularism. This relates to both the fundamental obligations of individuals and the premise of your directive. Politics and religion must be distinct from one another, and secularism really means removing religion from public life, if that is indeed the case.

There isn't an official state religion. The majority of Indians feel that faith and altruistic teaching form the foundation of the scriptures. All the principles of the religious texts incorporated into the school curriculum will become supportive when a secular culture is established. The governmental system supports all religions equally, does not discriminate between them, and may strategically enforce social benefits for all religions.

  1. Textbook on Interpretation of Statutes, Dr. A.B. Kafaltiya, 2nd edition, Universal, LexisNexis Publication.
  2. Interpretation of Statutes and Legislative Principles, Nayana A. Zope published on 1 January 2017, KSK Publishers and distributors.
  3. Vepa P. Sarathi's Interpretation of Statutes, Dama Seshadri Naidu, 5th edition, 2010, Reprinted 2022, Eastern Book Company
  4. The Constitution of India, P M Bakshi, 18th Edition, Universal, LexisNexis
  5. Concept of Secularism under Indian Constitution, Sara Elias, 2019 JETIR March 2019, Volume 6, Issue 3, (ISSN-2349-5162)
  6. Secularism and Religious Freedom in India: An Overview, Anas Jameel, International Journal of Creative Research Thoughts, 2021 IJCRT | Volume 9, Issue 3 March 2021 | ISSN: 2320-2882
  1. What is Political Theory and Why do we Need it? By Rajeev Bhargava
  2. AIR 1974 SC 1389
  3. Basu, A.M., et al. (2007) Religious Differentials in Child Survival in India: Some Unexpected Findings. Annual Meeting of the Population Association of America, New York, 30 March 2007.
  4. Rajeev Dhavan, "Religious Freedom in India," The American Journal of Comparative Law 35, no. 1 (February 17, 1987): 209�54,
  5. Deepa Das Acevedo, "Secularism in the Indian Context," Law & Social Inquiry 38, no. 1 (2013): 138�67,
  6. Sen, Articles of Faith: Religion, Secularism, and the Indian Supreme Court, 21
  7. Secularism: Why Indira ditched Nehru and inserted the S-word in the Constitution, Indian Express Journal of Courage, Written by Adrija Roychowdhury Atrija Roychowdhury, New Delhi, December 27, 2017. Available at:
  8. ibid
  9. O. Khalidi, "Hinduising India: Secularism in practice," Third World Q., 2008, doi: 10.1080/01436590802528614.
  10. 1962 AIR 853, 1962 SCR SUPL
  11. (1973) 4 SCC 225; AIR 1973 SC 1461
  12. Ramesh Yashwant Prabhu v. Prabhakar Kashinath Kunde, (1996) 1 SCC 130: AIR 1996 SC 1113: JT 1995 (8) SC 609: 1995 (7) SCALE 1: (1995) Supp 6 SCR 371
  13. 1954 AIR 282, 1954 SCR 1005
  14. Article 25(1) of Constitution of India
  15. (2017) 9 scc 1
  16. 984 AIR 512 1984 SCR (1) 447 1983 SCC (4) 522 1983 SCALE (2)565
  17. AIR 2000 SC 2773: (2000) 7 SCC 282: 2000 SCC (Cri) 1350
  18. 984 AIR 512 1984 SCR (1) 447 1983 SCC (4) 522 1983 SCALE (2)565
  19. A Common Denominator: The Role of the Anti-Exclusion Principle in Freedom of Religion Cases, Lucy Vickers, Professor of Law, Oxford Brookes University
  20. 1962 AIR 853, 1962 SCR SUPL. (2) 496
  21. Noorjehan Safia Niaz and Anr. v. State of Maharashtra and Ors. AIR 2017 (NOC) 45 (BOM.), 2016 (5) ABR 660 (2017) 7 ALLMR 408 (BOM)
  22. Indian Young Lawyers Association v. The State Of Kerala, AIRONLINE 2018 SC 243
  23. ibid
  24. [1994] 2 SCR 644 : AIR 1994 SC 1918 : (1994)3 SCC1
  25. AIR 2002 SC 3176
  26. (2006) 8 SCC 212
  27. 1987 AIR 748

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