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Religion In Army (Lieutenant Kamaleshan Case)

The case of Lieutenant Samuel Kamalesan involves the Indian Army's dismissal of a Christian officer for refusing to fully participate in his regiment's multi-faith religious parades, a decision recently upheld by the Supreme Court.

Case Background
  • Officer and Regiment: Lieutenant Kamalesan was commissioned into the 3rd Cavalry Regiment, a "fixed-class" unit with squadrons of Sikh, Jat, and Rajput soldiers.
  • The Conflict: Regimental tradition required officers to participate in all unit activities, including weekly parades at the on-premises temple and gurdwara, to foster morale and camaraderie. Kamalesan stated his Protestant Christian faith, which adheres to a monotheistic belief, prevented him from entering the inner sanctum (sanctum sanctorum) or performing puja (worship ritual) at other faiths' shrines. He was willing to be present in the courtyard but not engage in the specific rituals.
  • Army Action: The Army viewed his refusal, despite repeated counseling by senior officers and even a Christian pastor, as an act of "gross indiscipline" and a failure of leadership that undermined unit cohesion and troop morale. He was dismissed from service in March 2021 without a court-martial, pension, or gratuity.

The Court Rulings

Delhi High Court: Upheld the dismissal, stating that an officer had put his religion above a lawful command, which constituted indiscipline and violated "essential military ethos".

Supreme Court: In November 2025, the Supreme Court dismissed Kamalesan's appeal, refusing to interfere with the High Court's decision.
  • The bench called him a "misfit" and "cantankerous," remarking that an officer should not have a "private understanding" of what religion permits while in uniform.
  • Chief Justice Surya Kant noted that leaders must "lead by example" and that refusing to respect the sentiments of his troops was an insult to them.
  • The Court reinforced that military service involves sacrificing a measure of individual liberty for the sake of discipline and national security, a principle protected under Article 33 of the Indian Constitution, which allows the restriction of fundamental rights for armed forces personnel. 
 
The Ethos of Primacy of Duty

The core philosophy in institutions like the Indian Army is that "my religion is my soldier's religion".

 
  • Unit Cohesion over Personal Belief: The military's unique "secular" model focuses on harnessing collective faith as a unifying force, rather than the strict separation of religion from state institutions seen in some Western models.
  • Symbolic Leadership: Officers are expected to lead by example and demonstrate respect for the sentiments of their troops of all faiths. An officer participates in the unit's shared religious space not as a personal act of worship but as a gesture of solidarity and leadership.
  • Waiver of Fundamental RightsArticle 33 of the Indian Constitution allows for the modification or restriction of fundamental rights for armed forces personnel to ensure the proper discharge of their duties and the maintenance of discipline. The courts have consistently upheld that military standards of discipline are different from civilian standards. 

Leadership Expectations in Practice

The case of Lieutenant Kamalesan illustrates a direct application of these principles. His refusal to participate in the on-premises temple and gurdwara parades was seen by the Army and the courts as a failure of leadership and an act of indiscipline. 
  • Fostering Morale: Regimental traditions and religious parades serve a crucial motivational and psychological function in the Army, providing a shared anchor and connecting soldiers to centuries-old warrior traditions.
  • Avoiding Division: The military environment is designed to eliminate differences of caste, creed, and community, uniting personnel by their uniform. Allowing individual objections to override this could set a dangerous precedent, potentially leading to the questioning of other lawful commands and undermining the entire command structure.
  • Inclusivity through Participation: Past examples show officers of various faiths (Hindu, Muslim, Christian, Sikh) participating in all unit religious activities without conflict, seeing it as part of their duty to the men they command. 

Conclusion

In conclusion, the issue of religion within the military, as highlighted by cases such as Lieutenant Kamalesan's dismissal, pivots entirely on the principle of the "Primacy of Duty". 

The prevailing consensus, reinforced by judicial rulings, dictates that the unique operational environment of the armed forces necessitates a strict adherence to discipline and unit cohesion that overrides individual religious freedoms. 
 
 

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