New Delhi: In a strongly worded judgment that reasserts the primacy of military discipline over personal interpretation of religious doctrine, the Supreme Court on Tuesday (November 25, 2025) dismissed a plea filed by former Army officer Samuel Kamalesan challenging his termination from service. The bench, led by Chief Justice Surya Kant and Justice Joymalya Bagchi, upheld the Delhi High Court’s decision to validate the Army’s action, observing that the conduct of the officer, who refused to participate in regimental religious activities, was fundamentally incompatible with the ethos of the armed forces.
Calling the behaviour “the grossest kind of indiscipline”, the Chief Justice remarked that an officer entrusted with leading troops cannot selectively follow or reject practices considered essential for unit cohesion. “What kind of message has he been sending? He should have been thrown out for this only,” the CJI said, adding that a leader must lead by example and not “insult” the sentiments of the soldiers under his command.
The controversy stemmed from Mr. Kamalesan’s repeated refusal to enter the innermost sanctum of a temple located within the premises of the 3rd Cavalry Regiment, where he served as troop leader of the ‘B’ Squadron, comprising primarily Sikh soldiers. Although he accompanied personnel to both the temple and gurdwara during weekly religious parades, he refrained from entering the sanctum during aarti, havan or puja ceremonies, citing conflict with his Christian faith.
The officer argued that entering the sanctum would violate his religious conscience under Article 25 of the Constitution, even though he otherwise participated respectfully in multi-faith engagements. Senior advocate Gopal Sankaranarayanan, appearing for him, submitted that the Army had imposed the harshest penalty for what was essentially a single act of refusal.
The Supreme Court, however, rejected this defence, questioning where Christian doctrine explicitly bars entering a temple. “Article 25 protects essential religious features, not every sentiment. Where in the Christian faith is entering a temple barred?” Justice Bagchi asked.
The bench also took note of a local pastor’s advice reportedly given to the officer, which stated that entering a “sarva dharma sthal” or a place of reverence maintained for all faiths would not violate Christian principles. The judges said the officer’s refusal even after this counselling reflected an inflexible personal interpretation rather than an established religious mandate.
“When a pastor counselled you, you leave it at that. You cannot have your private understanding of what your religion permits. That too in uniform,” the CJI observed.
The Army, in its submission before the court, stressed that Mr. Kamalesan repeatedly refused to attend mandatory regimental parades despite “multiple attempts” by senior officers to guide him. His conduct, it argued, weakened unit cohesion, a core requirement for combat preparedness. The Army maintained that regimental religious structures such as temples or gurdwaras, though rooted in tradition, function as secular, unifying spaces meant to foster collective belonging rather than propagate denominational worship.
The bench highlighted this aspect during the hearing. Referring to the regiment’s gurdwara, the CJI said, “A gurdwara is one of the most secular places… The manner in which he is behaving, is he not insulting other religions?”
The court also underlined that the Indian Army is known globally for its secular and inclusive character, and officers are expected to respect the sentiments of their soldiers, especially in religiously diverse units.
“You may be outstanding in 100 things, but you have failed to respect the sentiments of your own soldiers,” the bench told the counsel, rejecting pleas for substituting the penalty of dismissal with a lesser punishment.
When the appellant’s counsel argued that not reversing the dismissal could send a wrong message to society, the CJI replied that the ruling would in fact “send a strong message” reinforcing the necessity of discipline and collective harmony in military life.
Commissioned in 2017, Mr. Kamalesan’s dismissal had previously been upheld by the Delhi High Court, which ruled that his conduct undermined the regiment’s cultural fabric. The Supreme Court, concurring, reiterated that personal faith cannot override institutional discipline, particularly in the armed forces, where unity of thought and action is critical for operational effectiveness.
