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Syed Khalique Ahmed

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New Delhi | Wednesday | 11 June 2025

Should a non-Hindu soldier in a predominantly Hindu or Sikh regiment be required to participate in temple rituals or lead prayers in a Gurudwara? Can refusal to perform such acts—if they conflict with one’s religious beliefs—be considered indiscipline? These questions lie at the heart of a recent ruling by the Delhi High Court, which upheld the dismissal of Lieutenant Samuel Kamalesan, a Protestant Christian, from the Indian Army.

Kamalesan led a squadron primarily made up of Sikh soldiers. He complied with regimental protocol to the extent of marching his troops to the Gurudwara each week. However, he declined to enter the sanctum sanctorum or lead prayers, citing that doing so violated his Christian beliefs. His request was simple: respect his personal faith without disrupting regimental cohesion. Yet, this act was interpreted by his superiors as insubordination. The court agreed, stating that Kamalesan had placed his religion above the "lawful command" of his officers.

This case is not just about one soldier. It raises serious concerns for the Indian Armed Forces, which are composed of personnel from various religions. While military discipline is essential, it must not come at the cost of violating fundamental rights guaranteed under the Indian Constitution—specifically, the freedom to practice one’s religion.

Kamalesan’s case brings into focus the military’s tradition-bound practices. For example, in regiments like the Rajput Regiment, it is customary to raise the battle cry “Bol Bajrang Bali ki Jai.” Can a Christian or Muslim soldier be forced to shout slogans invoking a deity that contradicts their religious beliefs? If they refuse, can they be penalized for indiscipline? Would a non-Muslim officer be compelled to lead the namaz if he led a squadron of Muslim soldiers, despite Islamic law barring non-Muslims from doing so?

Article at a Glance
The Delhi High Court recently upheld the dismissal of Lieutenant Samuel Kamalesan, a Protestant Christian, from the Indian Army for refusing to participate in temple rituals and lead prayers in a Gurudwara, citing his religious beliefs. Kamalesan complied with regimental protocol by accompanying his Sikh soldiers to the Gurudwara but declined to enter the sanctum sanctorum, which his superiors interpreted as insubordination. This case raises critical questions about the balance between military discipline and the constitutional right to religious freedom within the diverse Indian Armed Forces. Critics argue that enforcing regimental traditions at the expense of individual beliefs undermines the dignity and morale of soldiers. The ruling suggests that military tradition must prevail over personal faith, but it calls for a reevaluation of how the Army accommodates diversity. The military should explore inclusive practices that respect individual beliefs while maintaining cohesion, reflecting the secular values it is sworn to protect.

These are not abstract questions. They highlight the tension between the Army's need for uniformity and the constitutional guarantee of religious freedom. In this case, Kamalesan did not protest religious practices wholesale. By accompanying his troops to the temple grounds, he demonstrated respect for their faith. His only objection was being compelled to perform rituals that directly contradicted his own.

The ruling suggests that when an officer's religious beliefs conflict with military tradition, military discipline must prevail. But should it? If the command itself forces a soldier to violate a fundamental right, can refusal be considered a punishable offense?

Critics may argue that altering regimental traditions to accommodate individual beliefs could undermine discipline and create dangerous precedents. But this argument assumes that respect for diversity weakens cohesion. In fact, a more inclusive approach could strengthen trust and morale by affirming every soldier's dignity.

The military, while being the most disciplined institution in the country, should not be immune to constitutional scrutiny. If soldiers are asked to die for the nation, the least they deserve is the right to live according to their faith within its ranks. The idea that respect for individual belief compromises discipline must be revisited. Rather, discipline should accommodate diversity in a manner that respects both the collective ethos and personal integrity.

Kamalesan's case reflects a broader moral and institutional dilemma. He did not challenge the religious faith of his troops; he merely sought an exemption from active participation in rituals alien to his beliefs. His dismissal sends a troubling message: that to serve in the Indian Army, one might have to suppress one’s faith if it clashes with entrenched practices.

It is time for the armed forces to evolve. Regimental traditions should not become tools of exclusion or coercion. The Army must explore inclusive alternatives—like all-faith worship spaces or optional participation in rituals—to ensure no soldier feels marginalized.

India’s Constitution guarantees freedom of religion. This right must not stop at the gates of a cantonment. In a country where soldiers come from a tapestry of faiths, forcing conformity in matters of religion is neither constitutional nor ethical. Rather than enforce outdated norms, the Army should lead by example, reflecting the secular and pluralistic values it is sworn to protect.

A soldier’s faith should not be weaponized, nor viewed as a threat to discipline. It is, instead, part of the very freedom he has pledged to defend.

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