The Supreme Court of India is poised to tackle a profound question this Monday (October 5, 2025): Can military discipline and unit cohesion supersede an individual’s fundamental right to religious freedom? This query arises from a pivotal petition filed by a Christian Army officer who was terminated from service after he declined to enter the sanctum sanctorum of his regiment’s temple to perform a pooja, citing his religious beliefs.
A bench led by Justice Surya Kant will meticulously review the special leave petition submitted by Samuel Kamalesan. As a Lieutenant in the 3rd Cavalry Regiment, Kamalesan faced termination for what the Army deemed defiance of military discipline. His refusal stemmed from a superior officer’s command to enter the temple’s innermost part to conduct aarti, an act he believed conflicted with his monotheistic Christian faith.
The Delhi High Court had previously affirmed the Army’s decision in a May judgment, asserting that Mr. Kamalesan had ‘kept his religion above a lawful command from his superior,’ which constituted ‘an act of indiscipline.’ The High Court’s ruling emphasized that his actions violated ‘essential military ethos,’ underscoring a distinct operational dynamic within the armed forces compared to civilian life.
Represented by advocate Abhishek Jebaraj, Mr. Kamalesan clarified that his regiment comprised three squadrons of Sikh, Jat, and Rajput personnel, with him serving as a troop leader for one. He noted that the regiment had a mandir and a gurdwara for religious observances and parades, but lacked a ‘sarv dharm sthal‘ (a multi-faith prayer area) that would cater to all religious affiliations. Notably, there was no church within the premises.
Despite this, Kamalesan affirmed his participation alongside his troops in weekly religious parades at both the mandir and gurdwara. He also regularly attended various religious festivals celebrated by his unit, including Deepavali, Navaratri, Lohri, Gurpurab, and Holi. His request for exemption was specific: to avoid entering the innermost sanctum of the temple during pooja, havan, or aarti. He argued this was not only out of respect for his Christian faith but also out of deference to the sentiments of his troops. He maintained that he would still be present in the temple courtyard with his unit, observing all protocols like removing his shoes and belt, maintaining clean hands, and wearing a turban when required, from where he could respectfully view the rituals in the inner shrine as a full and integral member of the religious parade.
The Argument for Mutual Respect
Before the High Court, Mr. Kamalesan articulated that his deep bond with his fellow soldiers was built on ‘mutual respect, allegiance to the same Flag and Nation,’ and a shared sense of ‘Indianness,’ fostered through shared meals, exercises, living quarters, and assignments. He contended that the spirit of camaraderie and fraternity within the military extends far beyond mere participation in religious parades and activities.
Nevertheless, he recounted being repeatedly pressured by several senior officers to ‘choose between his faith and serving the Army.’ This culminated in his termination order, issued in March 2021.
Conversely, the Union government argued in the High Court that military personnel derive motivation, pride, and their distinctive war cries from devotional practices centered around a deity. They contended that an officer’s disengagement from these practices could significantly diminish troop morale, thereby jeopardizing regimentation, cohesion, and vital unity during combat operations.