RIGHT TO FREEEDOM OF RELIGION
(ARTICLE 25_28)
Introduction
India is a secular state. ----- The concept of secularism is implicit in the preamble of the constitution which declares the resolve of the people to secure to all its citizens “liberty to thought, belief, faith, and worship”. The 42th amendment act, 1976 has inserted the word “Secular” in the preamble. This amendment is intended merely to spell out clearly the concept of “secularism” in the constitution.
There is no mysticism in the secular character of the state. It only means that in matters of religion it is neutral. In India, a secular state was never considered as an irreligious or atheistic state. It only means that in matters of religion it is neutral. It is the ancient doctrine in India that the state protects all religions but interferes with none. Explaining the secular character of the Indian Constitution the Supreme Court said, there is no mysticism in the secular character of the state. Secularism is neither anti God nor pro God, it treat alike the devout, the antagonistic and the atheist. It eliminates God from the matters of the state and ensures that no one shall be discriminated against on the ground of religion. The state can have no religion of its own; it should treat all religions equally. The state must extend similar treatment to the church, the Mosque and the Temple. In a secular state, the state is only concerned with the relation between man and man. It is not concerned with the relation of man with God. It is left to the individual\’s conscience. Every man should be allowed to go to Heaven in his own way. Worshipping God should be according to the dictates of one’s own conscience. Man is not answerable to the state for the variety of his religious views. The right of worship was granted by God for man to worship as he pleased. There can be no compulsion in law of any creed or practice of any form of worship.
In S. R. Bommai V. Union of India[i][1] the Supreme Court has held that “secularism is a basic feature of the constitution” the states treat equally all religions and religious denominations. Religion is a matter of individual faith and cannot be mixed with secular activities. Secular activities can be regulated by the state by enacting a law. Justice Ramaswami observed that secularism is not anti-God. In the Indian context secularism has a positive content. The Indian Constitution embodies the positive secularism and has not accepted the American doctrine of secularism i.e., the concept of erecting “a wall of separation between Religion and state”. The concept of positive secularism separates spiritualism with individual faith. The state is neither anti-religion nor pro-religion. In the matter of religion, the state is neutral and treats every religion equally.
Sanskrit language not anti-secular
In a landmark judgment in Santosh Kumar v. Secy. Ministry of Human Resources Development[ii] the Supreme Court has held that introduction of Sanskrit language as a subject in the central Board of secondary Education (CBSE) is not against secularism as it is the mother of all Aryan languages. The court directed the CBSE to make necessary amendments in the syllabus within 3 months to make Sanskrit an elective subject for nurturing our cultural heritage.
The two judge bench of the court comprising Kuldip Singh and B. L. Hansaria, Jj, rejected the government’s contention that “by conceding to Sanskrit alone as an elective subject it would act against secularism. It also rejected the argument that if Sanskrit was introduced then Arabic and Persian would also have to be given similar status. The court said that without learning Sanskrit language it is not possible to “decipher” Indian philosophy, culture and heritage. All teaching of Shankaracharya, Ramanuja, Madhawacharya, etc would not have been possible without this language. This is the Historical relevance of the ancient language.
Secularism means developing, understanding and respect for different religions
In Aruna Roy V. Union of India,[iii] the validity of the new national Education policy, 2002 which provided for value based education to school children based on basis that study of religions in school education is not against the secular philosophy of the constitution. Justice Dharmadhikari said that form the experience of the working of constitution for more than 50 years it is clear that the complete neutrality towards religion and apathy for all kinds of religious teachings in institutions of state have no helped in removing mutual misunderstanding and intolerance inter se between sections of the people of different religions, faith and beliefs. Secularism therefore is susceptible to positive meaning that is developing, understanding and respect towards different religions.
The essence of secularism in non-discrimination of people by the state on the basis of religious differences. Secularism can be practiced by adopting a complete neutral approach towards religions or by positive approach by making one section of religious people to understand and respect religion and faith of another section of people. Based on such mutual understanding and respect for each other’s religious faith, mutual distrust and intolerance can gradually be eliminated. His lordship quoted Gandhiji who said “the real meaning of secularism is Srva Sharma Sambhav meaning equal treatment and respect for all religions.
The right to freedom of religion allows Indian citizens to choose any religion that he / she wants to choose. This fundamental right was chosen after lot of thought regarding the process of person choosing his / her own religion. This fundamental right is described in the constitution as:
The right to freedom of religion is a fundamental right guaranteed under Article 25 of the Constitution of India. Article 25 reads as follows:-
Article 25. (1). Subject to public order, morality and health and to the other provisions of this Part, all persons are equally entitled to freedom of conscience and the right freely to profess, practice and propagate religion.
Article 25. (2). nothing in this article shall affect the operation of any existing law or prevent the State from making any law: -
(a) Regulating or restricting any economic financial political or other secular activity which may be associated with religious practice;
b) Providing for social welfare and reform or the throwing open of Hindu religious institutions of a public character to all classes and sections of Hindus.
This Article guarantees that every person in India shall have the freedom of conscience and shall have the right to profess, practice and propagate religion, subject to the restrictions that may be imposed by the State on the following grounds, namely:-
(1) Public order, morality and health;
(2) Other provisions of the Constitution;
(3) Regulation of non-religious activity associated with religious practice;
(4) Social welfare and reform;
(5) Throwing open of Hindu religious institutions of a public character to all classes of Hindus.
What is religion? The term religion is not defined in the constitution and indeed it is a term which is hardly susceptible to any rigid definition. The Supreme Court has defined it broadly. Religion is a matter of faith with individuals or communities and it is not necessarily theistic. Religion has its basis in a system of belief’s or doctrines which are regarded by those who profess that religion as conducive to their spiritual well being. But it will not be correct to say that religion is nothing else but a doctrine of belief. A religion may only lay down a code of ethical rules for its followers to accept. It might prescribe rituals and observances, ceremonies and modes of worship which are matters of food and dress. Religion is thus essentially a matter of personal faith and belief. Every person has right not only to entertain such religious belief and ideas as may be approved by his judgment or conscience but also ezhibit his belief and ideas by such overt acts which are sanctioned by his religion. Thus under article 25 (1) a person has a two hold freedom
(a) Freedom of conscience;
(b) Freedom to profess, practice and propagate religion.
The freedom of conscience is absolute inner freedom of the citizen to mould his own relation with God in whatever manner he likes when this freedom becomes articulate and expressed in outward form it is to profess and practice religion. To profess a religion means to declare freely and openly one’s faith and belief. He has right to practice his belief by practical expression in any manner he likes. To practice religion is to perform the prescribed religious duties, rites and rituals, and to exhibit his religious beliefs and ideas by such acts as prescribed religious order in which he believes. To propagate means to spread and publicize his religious view for the edification others. But the word propagation only[iv]u indicates persuasion and exposition without any element of coercion. The right to propagate one’s religion does not give a right to convert any person to one’s own religion. There is no fundamental right to convert any person to one’s own religion. What Art. 25 (1) guarantees is not right to convert another person to one’s own religion, but to transmit or spread one’s religion by an exposition of its tenets. Article 25 guarantees “freedom of conscience” to every citizen, and not merely to the follower of one particular religion. It, therefore, postulates that there is no fundamental right to convert another person to one’s own religion because if a person purposely undertakes the conversion of another person to one’s own religion because if a person purposely undertakes the conversion of another person to his religion, as distinguished from his effort to transmit or spread the tenets of his religion that would impinge on the “freedom of Conscience” guaranteed to all the citizens of the country alike.
The protection of Articles 25 and 26 is thus not limited to matters of doctrine of belief. It extends also to acts done in pursuance of religion and therefore contains a guarantee for rituals and observances, ceremonies and modes of worship which are integral part of religion. What constitutes an essential part of religions or religious practice has to be decided by the court with reference to a doctrine of a particular religion and include practices which are regarded by the community as a part of its religion.
In judgment of far reaching importance in the National Anthem Case[v] the Supreme Court has held that no person can be compelled to sing the National Anthem “if he has genuine, conscientious religious objection”. In the instant case, three children belonging to the “ Jehova’s witnesses of the Christian community were expelled from the school for refusing to sing the National Anthem. They challenged the validity of their expulsion on the ground that it was violative of their fundamental right under Article 25 (1) a circular issued but the Director of public instructions had made it compulsory for all children in schools to sing the National Anthem. They had stood up respectfully when the National Anthem was being sung every morning at their school but they did not join in the singing of it. They refused to sing the National Anthem as according to them it was against the tenets of their religious faith which did not permit them to join in any rituals except if it be in their prayer to Jehovah, their God, The Kerala High Court held that was their fundamental duty under constitution to sing the National Anthem. It held that if the pupil belonging to the religious group refused to participate in the singing of the National Anthem it would have a very bad influence on the other pupils and the head mistress was therefore within her right not to permit them to attend the class until they gave in writing that they will participate in the singing of the National Anthem in the school, the high court said, would endanger the security of the nation in that the same will develop among the citizens a tendency to ignore the mandates of the constitution thereby defeating the object (discernible from the preamble and other provisions) to accomplish which the people gave the constitution themselves. If religious practices run counter to public order, morality, health or a policy of the Government to uphold the sovereignty and integrity and unity of the nation then they said religious practices must give way for the benefit of the people and the nation as a whole.
On appeal, however, the Supreme Court reversed the High Court decision and held that there is no obligation in India for a citizen to sing the National Anthem. The right under Article 25 (1) cannot be regulated by executive instructions which had no force of law. The court said that by standing up while the National Anthem was being sung the children had shown proper respect to the national Anthem and had thus not violated the fundamental duties laid down in Article 51-A of the constitution. Their conduct did not amount to an offence under the prevention of insults of National Honor Act, 1971 as they did not prevent the singing of the National Anthem. Accordingly, the court directed the authorities to re-admit the children in the school and to allow them to pursue their study.
Non Brahmins can be appointed as Pujari in temple
In a judgment,[vi] of far reaching consequence the Supreme Court has held that Brahmins do not have monopoly over performing Puja in a temple and said that a non-Brahmins can be appointed as a Pujari if he is properly trained and well versed with rituals, this ruling was given by a bench comprising justice S. Rajendra Babu and Justice Doraiswami Raju while upholding the appointment of a non-Brahmin as Pujari in Kongoopilly neerikoda Siva Temple at Alangad village in Erankulam, Kerala, Justice Raju said “ it therefore goes without saying that what is required and expected of one to perform the ritual and conduct poojas is to know the rituals to be performed and mantras, as necessary to be recited for the particular deity.
The court said if traditionally or conventionally in any temple, all along a Brahmin alone was conducting puja or performing the job o Santikaran (pujari) it might not be because a person other than the Brahmin was prohibited from doing so because he was not a Brahmin. It might be because others were not in a position and, as a matter of fact, were prohibited from learning rituals or mastering Vedic literature, rites or performance of rituals and wearing screed thread by getting initialed into the order. So there no justification in insisting that a Brahmin or malayali Brahmin in this case, alone can perform the rites and rituals in the temple as part of the rights and freedom guaranteed under Article 25 of the constitution and further claim that any deviation would be tantamount to violation of any such guarantee under the constitution.
In Ismail Farqui V. Union of India the Supreme court by a majority has held that the state can in exercise of its sovereign power acquire places of worship like mosques, churches, temples.etc. which is independent of Article 300 –A of the constitution if it is necessary for maintenance of law and order. Such acquisition per se does not violate Article 25 and 26 of the constitution. What is protected under Article 25 and 26 is a religious practice which forms an essential and integral part of religion. A practice may be a religious practice but no an essential part of religious practice. While offer of prayer or worship is a religious practice, its offering at every location where such prayers can be offered would not be an essential religious practice.
In two landmark judgments on freedom of religion under Article 25 and 26 of the constitution in A. S Narayana V. State of Andhra Pradesh[vii], and Vaishno Devi Shrine, cases the Supreme court has clearly defined the role of the state in the matter of religion.
In Gulam Kadar Ahmadbai Menon V. Surat Municipal Corporation, the Gujarat high court has held that the right to religion guaranteed to citizens under Acts. 25 and 26 of the constitution does not prohibit state to acuire any place of worship for public purpose. In this case the petitioners had challenged the validity of section 12 of the Bombay Provincial Municipal Corporation Act 1949. Under the Act the Municipal Corporation had ordered the demolition of some parts of the two mosques situated in main road of Sort district in the state of Gujarat. The court held that the acquisition of a religious place or a part thereof is not prohibited by the Constitution and therefore can be order for the demolition of certain portions of the two mosques for widening the road was valid.
Noise Pollution in the name of Religion not allowed
In a significant judgment in church of God (full gospel) in India V. K.K.R.M.C welfare Association, the Supreme Court has held that in the exercise of the right to religious freedom under Article 25 and 26, no person can be allowed to create noise pollution or disturb the peace of others. The custom of religious prayer through the use of loudspeakers is not an essential element of any religion. In that the applellant is the church of God located at K.K.R Nagar, Madhavaram, High Road, Chennai. It has a prayer hall for the Pentecostal Christians and provided with musical instruments such as drums set, triple bango, guitar etc. the K.K.R Majestic Colony welfare Associations made a complaint to the Tamilnadu Pollution Control Board stating therein that prayers in the church were recited by using loudspeakers, drums and other sound producing instruments causing noise pollution and nuisance to the normal life of the residents of the said colony. The Madras High Court directed the police authorities to take action to stop noise pollution. On behalf of the church it was contended that its religious activities and the court cannot prevent the church from practicing religious beliefs. It was also said that noise pollution was die to plying of vehicles and not due to use of loudspeakers etc. the Supreme Court held that a person’s religious freedom is subject to “public order, morality and health”. Even if there is any such court said that “no rights in an organized society can be absolute” in view of this the order of the authorities under the Madras Town Nuisance Act, 1989 and the Noise pollution (Regulation and Control) Rules, 2000 is valid and constitutional.
Restrictions on Freedom of Religion:
(1) Religious liberty subject to public order, morality and health.--- in the name of religion no act can be done against public order, morality and healthy of the public. Thus section 34 of the police Act prohibits the slaughter of cattle or indecent exposure one’s person in public place. These acts cannot be justified on plea of practice of religious rites. Likewise, in the name of religion untouchability or traffic in human beings e.g. system of Devadasis (as prevalent in south India) cannot be tolerated. This freedom is also subject to the “other provisions of this part”, e.g. Right to freedom of speech and expression, freedom of assembly and association, freedom to carry on a profession, trade and business. The freedom to practice religion cannot affect the exercise of these freedoms by others. These rights are subject to the reasonable restrictions under clause (2) of Article. 19.
Right to propagate one’s religion does not give right to anyone to “forcibly” convert any person to one’s own religion. Forcible conversion of any person to one’s own religion might disturb the public order hence could be prohibited by law.
Forced conversion not allowed
In Rev Stainislaus Vs. State of M.P the validity of the two act –the Madhya Pradesh Dharma Swatanrya Adhinyam. 1968 and Orissa freedom of Religion Act 1967 passed by state legislatures of Madhya Pradesh and Orissa respectively was challenged on the ground that they were violative of the fundamental right of the appellant guaranteed under Article 25 (1) of the constitution. These Acts were passed to prohibit forcible conversion of any person to one’s won religion. The appelland was prosecuted for the commission of offences under the Madhya Pradesh Act. He contended that right to “propagate” one’s religion meant the right to convert person to one’s own religion and was a fundamental right under Article 25 (1) of the constitution. Secondly, he argued that the state Legislature had no competence to enact such a law as it did not fall within the purview of Entry I so parliament alone had the power to make the law and not the state Legislature.
Rejecting the contentions of the appellant the supreme court held that impugned Act fell within the purview of Entry I of list II as they were meant to avoid disturbances to the public order by prohibiting conversion from one’s religion to another in a manner reprehensible to the conscience of the community. These two Act do not provide for the regulation of religion and therefore do not fall under Entry 7 of list I. Dealing with the meaning of the words “public order” the court held that if a thing which disturbs the current of the life of the community. And does not merely affect an individual it would amount to disturbance of the public order. Thus if an attempt is made to raise communal passions, e.g., on the ground that someone has been “forcibly” converted to another religion, it would, in all probability, give rise to an apprehension of a breach of the public order, affecting the community at large. Therefore, legislation prohibiting forcible conversion of one’s own religion in the interest of public order can be passed and is valid.
(2) Regulation of economic, financial, political and secular activities associated with religious practices—Clause (2) (a) – the freedom to practice extends only to those activities which are the essence of religion. It does not cover secular activities which do not form the essence of religion. It is not always easy to say which activities fall under religious practice or which are of secular, commercial or political nature associated with religious practice. Each case must be judged by its own facts and circumstance. In Mohd. Hanif Quareshi Vs. State of Bihar,[viii] the petitioner claimed that the sacrifice of cows on the occasion of Bakrid was an essential part of his religion and therefore the state law forbidding the slaughter of cows was the sacrifice of cow on the Bakrid day was not an essential part of Mohammaden religion and hence could be prohibited by state under clause (2) (a) of Article 25. In Adelaid Co Vs. Commonwealth,[ix] it was held that a person could not be allowed in exercise of his freedom of religious practice and profession to carry on an anti-war propaganda in the guise of religion belief by a particular organist ion were held not to be protected by the constitution.
(3) Social welfare and social reforms—Clause (2) (b)—under clause (2) (b) of Article 25 the state is empowered to make laws for social welfare and social reform. Thus under this clause the state can eradicate social practices and dogmas which stand in the path of the countries onwards progress. Such laws do not affect the essence of any religion. This clause declares that where there is conflict between the need of social welfare and reform and religious practice, religion must yield. Social evils cannot be practiced in the name of the religion. In state of Bombay vs. Varasu Bapamli,[x] an act which prohibited bigamy was held valid under clause (2) (b), Polygamy is not an essential part of the Hindu religion, therefore it can be regulated by law. In an American case of Rynolds Vs. United states, [xi] a state law made it a criminal offence to marry with another while having a living spouse. The appellant was punished for attempting to take a second wife under the sanction and command of his religion. The Supreme Court held that his punishment was valid under the statute which prohibited bigamy. The court said “Congress was deprived of all legislative power over mere opinion but was left free to reach actions which were in violation of social duties or subversive of good order”. Prohibition of civil practices such as Sati or system of Davadasi has been held to be justified under clause.
Freedom to manage religious affairs (Article 26) _Article 26 says that subject to public order, morality and health every religious denomination of any section it shall have following rights,
1. To establish and maintain institution for religious and charitable proposes
2. To manage its own affairs in the matter of religious
3. To own an acquire moveable and immoveable property
4. Do administer such a property in according to law
The right guaranteed by article 25 is an individual right while right guaranteed by article 26 is the right of an organize body and religious denomination or any section thereof. In Webster dictionary, the word “denomination” has been defined as “collection of individual, classed together under the same name” generally a religious sect or body having a common faith and organization and designated by a distinctive value, the words “religious denomination” in Article 26 must take their colour from the word “religion” and therefore it must also satisfy three conditions: (1) it must be a collection of individual who have a system of beliefs which they regard as conducive to their spiritual well being, that is, a common faith; (2) it must have a common organization; and (3) it must be designated by a distinctive name, thus in the large sense, the “Hinduism” is a denomination in contradistinction to Christians and Muslims. In limited “sense” the various philosophies governing the Hindu society, such as Advaitas, Dwaitas Vishistadwairts and Saivites can also be termed as denomination, likewise, it has been held that “Ananda Marga” is a religious denomination within the Hindu religion.
Right to establish and maintain---institution for religious and charitable purpose__ under clause (a) of Article 26 every religious denomination has right to establish and maintain institutions for religious and charitable purposes. The words establish and maintain in Article 26 (a) must be read together and therefore it is only those institution which a religious denomination establishes which it can claim to maintain it. Thus in Azeez Bashu V. Union of India the Supreme Court held that the Aligarl, University was not established by the Muslim minority and therefore it could not claim the right to maintain it. It was established under the statue passed by parliament.
Right to manage matters of Religion: --- under Article 26 (b) a religious denomination or organization is free to manage its own affairs in matters of religion. The state cannot interfere in the exercise of this unless they run counters to public order, health or morality, accordingly every religious denomination or organization enjoys complete freedom in the matters of deciding what rites and ceremonies are essential according to the tenets of the religion they hold. The court, has the right to determine whether a particular rite or ceremony is regarded as essential by the tenets of a particular religion.
The right is, it is noted, confined to matters of religion. The term matters of religion includes religious practices, rites and ceremonies considered essential for practice of religion. The right is, however, subject to the regulatory power of the state under clause (2) (b) of Article 25. This means that secular activities connected with religious institutions can be regulated by state law. The places of worship like temples mosques, gurudwaras cannot be used for hiding criminal or carrying on anti-national activities. They cannot be used for political purpose. The state has power under Article 25 (1) and clause (2) to prohibit these activities in the places of worship; the state cannot be a passive spectator when exercise of right of religion threatens the public order, morality and health of the community.
It must play a positive role and ensure maintains of public order, health and morality in the society. The constitution requires not only that the state will be away from religion but also imposes a positive duty on the state to free may aspects of our life from the control of religion. The provisions of the constitution are very clear in this respect. This state is not expected to remain a mere passive spectator when the freedom of religion is being used against the interest of society and the nation as whole.
Freedom from taxes for promotion of any particular religion__ Article 27
Article 27 provides that no person shall be compelled to pay any tax for the promotion or maintenance of any particular religion or religious denomination. This Article emphasizes the secular character of the state. The public money collected by way of tax cannot be spent by the state for the promotion of any particular religion.
The reason underlying this provision is that India being a secular state and there being freedom of religion guaranteed by the constitution both to individual and groups it is against the policy of the constitution to pay out of public funds any money for the promotion or maintenance of the particular religion or religious denomination. It is to be noted here that what this Article prohibits is the levying of tax and not of fee. In Rati Lal Vs. State of Bombay,[xii] the Supreme court has held that a tax is in the nature of a compulsory exaction of money by a public authority for public purposes. The imposition is made for public purpose to meet the general expenses of the state without reference to any special advantage to be conferred upon the tax payer. Tax is a common burden and the only return which the tax payer gets is a participation in the common benefits of the state. Fees are, on the other hand, payments primarily in public interest but for some special series rendered or some special work done for the benefit of those from whom the payments are demanded. In determining whether a lavvy is a fee, the true test must be whether its primary and essential purpose is to render specific services to a specified area benefited by it. The traditional view that there must be actual quid pro quo for a fee has undergone a great change. The element of quid pro quo in the strict sense is not always a expected is one of general character and not of mathematical exactitude. All that is necessary is that there should be reasonable relationship between the levy of the fee and the services rendered.
On the basis of distinction between tax and fee the Supreme Court in Sri Jagannath Vs. State o fOrissa,[xiii] held that the levy under the Orissa Hindu religious Endowments Act, 1939, was in the nature of a fee and not tax. The payment was demanded only for the purpose of meeting the expenses of the commissioner and his office which was the machinery set up for due administration of the affairs of the religious institution. The object of the contribution was not the fostering or preservation of Hindu religion or of the denomination within it, but to see that religious institution were properly administered.
The prohibition is against giving aid to any particular religion. This means that if state aid is extended to all religious institution along with secular ones alike without any discrimination, Article 27 will not be applicable.
Prohibition of religious instruction in state –aided institution—Article 28
According to Article 28 (1) no religious instruction shall be imparted in any educational institution wholly maintained out of state funds. But this clause shall not apply to an educational institution which is administered by the state but has been established under any endowment or trust which requires that religious instruction shall be imparted in such institution. Under clause 1 (3) no person attending any educational institution recognized by the state or receiving aid out of state funds shall be required to take part in any religious instruction that may be imparted in such institution or to attend any religious worship that may be conducted in such institution or to any premises attached thereto unless such person or if such person is a minor his guardian has given his consent thereto, thus Article 28 mentions four types of educational institution:
(a) Institution wholly maintained by the State
(b) Institution recognized by the State.
(c) Institution that are receiving aid out of the State funds.
(d) Institution that are administered by the state but are established under any trust or endowment.
In the institution of (a) type no religious instruction can be imparted. In (b) and (c) type institutions religious instruction may be imparted only with the consent of the individual. In the (d) type institutions, there is no restriction on religious instructions.
In D. A. College, Jullundhar Vs. State of Punjab,[xiv] the validity of section 4 of the Guru Nanak University Act which directed the state to make provision for the study and research on the life and teaching of Guru Nanak was challenged on the ground that it was violative of Article 28 which prohibited religious instruction in state aided educational institutions. The court rejected the contention and held that section 4 which enjoined the university to encourage an academic study of the life and teaching of Guru Nanak does not amount to religious instructions or promotion of any particular religion and therefore is constitutionally valid.
Footnote
[ii] - AIR 1995 SC 293
[iii] - AIR 2002 SC 3176.
[iv]- Rev Stainislaus V. state of MP AIR 1977 Sc 908
[v] - Bojoe Emmanual V. State of Kerala (1984) JSCC
[vi] - N Aditya V. Travamcore Dewasom Board
[vii] - AIR1996 SC 1765
[viii] - AIR 1958 SC 731
[ix] - (1943) 67 CLR 116
[x] - AIR 1953 Bom. 84
[xi][xi] - 98 US 145 L.Ed 544 (1987)
[xii] - AIR 1954 SC 388
[xiii] - AIR 1954 SC400
Bibliography
1. Dr. PANDEY, J.N., THE CONSTITUTION OF LAW OF INDIA, 2009, 46TH Edition, Central law Agency, Allahabad, Delhi.
2. Dr. PRANJAPE, N.V., INDIAN LEGAL & CONSTITUTIONAL HISTORY, Central law Agency, Allahabad, Delhi.
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