Can an Army officer refuse to step into a place of worship that matters deeply to his troops, and still expect to lead them?
That is the question at the heart of the Supreme Court’s decision in Lt Samuel Kamalesan v Union of India after the CJI-led bench upheld the dismissal of a young Christian officer who refused to enter a gurdwara's sanctum sanctorum with his Sikh soldiers during routine unit ceremonies, because of his Protestant Christian beliefs.
What the Supreme Court decided
On 25 November 2025, a bench of CJI Surya Kant and Justice Joymalya Bagchi dismissed Kamalesan’s plea challenging his dismissal from the Army. The apex court refused to interfere with a Delhi High Court order from May that had already upheld the termination.
The top court’s key observations:
- His conduct amounted to 'the grossest kind of indiscipline.'
- He was 'absolutely a misfit for the Indian Army,' even if otherwise competent.
- He carried a 'religious ego so high that you don’t care about others.'
- An officer must respect the religious faith of the soldiers he commands in a secular Army.
“Is this sort of cantankerous conduct permissible in a disciplined force?” the CJI asked.
The language was sharp, but the underlying concern was institutional: secularism, trust, and respect for sentiments of officer and soldier.
Net result: His 2017 dismissal stands, without pension or gratuity.
How Army veterans view the judgment
Retired Lt Gen Deependra Singh Hooda, former Northern Army Commander who oversaw operations along the Pakistan and China borders, told Moneycontrol that the core issue is not about ritual, but trust.
“The Indian Army’s professional ethos rests very largely on the relationship between the officers and their soldiers. When soldiers unhesitatingly obey the command of an officer to go into a situation which could lead to their death, it is because they have complete confidence and trust in his leadership. Anything that could weaken this trust must be curbed," he told Moneycontrol.
He also added that this is not a matter of religious faith, but a more fundamental issue of the values, character, and professionalism of the army. "I think we should look at the Supreme Court judgment from this perspective. If we allow our religious rigidity to seep into the uniform, the concept of brotherhood that has sustained the army through wars and conflict will be completely diluted. This would be a national loss.”
Retired Lt Gen Kanwal Jeet Singh Dhillon, former XV Corps Commander, reacted to the controversy by reposting a tweet supporting the verdict. In another post, he reacted strongly to a user who questioned the Supreme Court verdict, wondering whether the Indian Army would throw out an officer who is an atheist.
“‘IF’ !!! The whole agenda driven post started with an assumption ‘If’, that only proves the agenda propagator knows the truth is very different. Indian Army @adgpi is much beyond and higher than your biases and assumptions, sir. May God bless you," he said.
Retired Major General Raju Chauhan wrote on X that the Army is one of India’s strongest symbols of secularism, soldiers of all identities serve together, bound by duty and discipline.
He added that the Supreme Court’s decision is 'in sync with these ethos.'
Retired Brig Sandeep Thapar, a Sikh Regiment veteran with over 36 years in service, posted on X: “In my 38 years in uniform, never heard of any officer not accepting the faith of his troops. You don’t have to adopt that religion, just follow the basics.”
In a follow-up post, he explained why this matters:
- Army units fight on regimental pride, 'namak aur nishan.'
- A jawan will follow an officer into battle only if he feels the officer is his own.
- Officers train, eat, suffer and pray with their men, not to convert but to earn trust.
- Participating in key rituals is a core part of command; without it, trust erodes.
However, a retired lieutenant general of the Indian Army, who wished not to be named, offered a sharply different view. He told Moneycontrol that the matter was badly handled and should never have escalated to this point.
According to him, “Every unit must have a proper Sarva Dharma Sthal. Even if an officer has conservative or orthodox beliefs, he should be counselled and guided, not pushed into a corner. And even if he still doesn’t comply fully, it’s not a big issue."
He said that the Indian forces have officers from many religions, adding that they must actively celebrate all faiths and build a culture where an officer who is not Sikh or Hindu feels comfortable participating, and can also share aspects of his own religious tradition to foster inclusivity.
"This case was poorly handled, and the Supreme Court was too harsh. If an officer is willing to serve and lead with full commitment, one instance of refusing a ritual shouldn’t overshadow his career. Let it be,” he told Moneycontrol.
On whether visible participation in religious rituals affects troop trust, he said: “Jawans don’t care about these things. What matters to them is whether their officer is competent, can take pressure, and can face danger with them.”
What exactly happened: the crux
Lt Samuel Kamalesan, commissioned in 2017 into the 3rd Cavalry, led a troop of mostly Sikh soldiers. His regiment had a long-standing practice: weekly visits to a Sarva Dharma Sthal, temple, or gurdwara, a ritual meant to boost morale, foster identity, and promote bonding.
As per Army and court records, he:
- Refused to enter the shrine with his troops
- Stood outside, declined to offer flowers or join aarti/havan
- Ignored repeated counselling at different levels
- Continued to refuse even after a pastor in Chandigarh said this did not violate Christian doctrine
The Army treated this as disobedience of a lawful command and a breach of its secular norms. He was dismissed in 2017.
What Kamalesan said
Relying on Article 25, he argued that:
- His Protestant faith bars him from worshipping any other deity
- He was willing to be present, but not enter the sanctum
- There was no true Sarva Dharma Sthal at his posting, only a temple and gurdwara
- The Army’s own caste/community-based regiments undercut its claim of strict secularism
The Delhi High Court stated that he had prioritised religion over a lawful command, 'clearly an act of indiscipline.' It held that an Army 'united by its uniform' cannot afford such conduct, which harms trust and camaraderie
The Supreme Court took an even harder line: calling him 'cantankerous,' 'a misfit,' and that his refusal insulted his own troops and held that Article 25 cannot override military discipline. It reiterated that courts will not micromanage how the Army enforces discipline
Core takeaway: In the Court’s view, an officer cannot visibly distance himself from his men during shared rituals and still expect to command them.
What this says about secularism in uniform
Historically, the Army’s secularism is functional, not doctrinal. The Sarva Dharma Sthal, shared space for multiple faiths, is the Army’s standard way to square religious diversity with unit cohesion.
Both the Delhi High Court and the Supreme Court agreed that joining troops in such rituals is part of command, not an optional extra. In that frame, an officer’s religious discomfort cannot justify a public display of distance from his unit.
By sidestepping a deep Article 25 analysis or any restructuring of regimental practice, the Supreme Court stayed with precedent: the armed forces are judged by a different standard than civilian workplaces. In uniform, fundamental rights are narrowed by the perceived imperatives of discipline, cohesion and command.
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