The dismissal of Lieutenant Samuel Kamalesan, upheld by the Supreme Court of India, highlights the core tension between individual religious freedom and the institutional needs of military discipline, leadership, and unit cohesion. The case is not about religion itself but about an officer’s refusal to follow regimental practices seen as vital for morale and effectiveness command.
The Voluntary Compact of Service
The Indian Armed Forces are a voluntary service where recruits accept a distinct legal and institutional framework. Military service features a hierarchical command structure and restrictions on certain individual rights to ensure discipline and operational effectiveness. When officers are commissioned, they swear an oath that emphasises duty, lawful command, and readiness to face danger over personal preferences. Within this system, an officer’s refusal to participate in regimental religious observances is considered a breach of discipline and leadership responsibilities.
Implications for Soldiers
For the ordinary soldier, often from rural backgrounds steeped in tradition and faith, regimental religious observances mean far more than mere ritual; they serve as the emotional glue that binds the unit into a family capable of facing the horrors of combat.
When an officer stands apart, refusing to join in these shared moments, it signals to jawans that their leader values personal conviction more than collective solidarity, eroding the trust soldiers have in those who lead them into danger.
This fracture in perceived unity can lower morale, weaken instinctive obedience under stress, and subtly undermine the willingness to make the ultimate sacrifice, as troops question whether their Sahab truly stands with them in times of vulnerability.
The Supreme Court’s verdict thus protects the soldier’s psychological resilience by mandating a leadership standard that requires participation in regimental traditions, reassuring the ranks that no faith-based or other divides will weaken the chain of command when bullets fly.
Implications for Minority Communities
Minority communities, including Christians, Muslims, and others, have long served honourably in the Indian Armed Forces despite their under-representation relative to population proportions. Muslims make up around 3 percent of the Army despite comprising 14 percent of India’s population, and Christians form a small but dedicated cadre in regiments like the Kumaon and Naga units. The Kamalesan verdict does not create barriers to their entry or service; instead, it emphasises that integration into the regimental system requires reciprocal participation in collective traditions, fostering a sense of belonging that has historically allowed minority officers to rise through the ranks and effectively command units with a majority demographic.
This ethos of mutual accommodation, where a Christian officer leads Hindu prayers or a Muslim subaltern joins Gurudwara ceremonies, strengthens minority retention and advancement by demonstrating their commitment to the unit over personal faith, countering any narrative of exclusion and ensuring that diverse recruits see the Army as a meritocratic equaliser rather than a culturally alien space. Far from discouraging minorities, the ruling affirms the very pluralism that has supported their contributions across decades of conflict.
The officers in units with Muslim troops follow all the tenets of Islam, irrespective of their personal religion.
Regimental Ethos and Practice
The Army’s ethos has long balanced religious diversity with strong unit traditions. Many units with deep regional, caste, or community identities observe religious customs aligned with the majority of their troops. Officers, regardless of personal faith, are expected to participate in these observances as symbols of solidarity and respect rather than as acts of religious worship. These rituals, such as joining prayers at temples, gurudwaras, or the Sarva Dharma Sthal, primarily serve to build esprit de corps and shared identity.
Judicial Recognition of Cohesion
The courts, including the Supreme Court, acknowledged that these practices are vital for morale and regimental pride. Refusing to participate in such rituals endangers the cohesion necessary for effective military operation and damages leadership credibility. The bench emphasised the importance of officers “leading by example” and observed that Kamalesan’s refusal was equivalent to undermining the unity of the troops he commanded.
Constitutional Balance
From a constitutional perspective, Kamalesan invoked Article 25, which guarantees freedom of religion, arguing that his refusal was protected. The courts, however, rejected this, citing that the Indian Armed Forces operate under Article 33, which allows reasonable restrictions on fundamental rights to maintain discipline and ensure operational effectiveness. The judgment clarified that not all personal religious beliefs are protected when they clash with military obligations, especially when they involve collective practices considered necessary to the institution’s functioning.
Battle-Winning Factors
Discipline, morale, and cohesion are key factors in winning battles. Military theory and experience confirm that trust and shared purpose among soldiers are crucial for combat effectiveness. Regimental religious ceremonies are included in institutional life because they build collective identity, loyalty, and readiness to face challenges.
The idea that “there are only winners in combat, no seconds” highlights the importance of total unity, as visible separation between officers and troops weakens the fighting spirit.
Counterarguments and Institutional Stance
Opposing views argue that forced participation in religious activities infringes on individual conscience and threatens secularism within the armed forces—some advocate for secular, non-religious practices to maintain unity without religious symbols. However, the current judicial and institutional stance in India emphasises tradition-based cohesion and discipline, viewing religious observances as professional routines rather than mandatory worship.
Operational Secularism
The Indian Army does not carry out operations based on religious mandates, nor does it label casualties as martyrs in a theological context.
The use of religious symbols within regiments is meant to promote unity among different faiths under a common institutional identity. The Kamalesan case confirms that institutional values and leadership duties are prioritised over personal religious interpretations when they conflict with military discipline.
Key Takeaways
In summary, the case emphasises the unnegotiable importance of military discipline and leadership standards over individual religious freedoms in service. The armed forces establish a distinct constitutional space where certain rights are lawfully limited to preserve cohesion and effectiveness. Regimental rituals, although religious in appearance, are regarded as professional practices essential for morale and unity. Officers have a heightened duty to participate and lead by example, representing their units’ collective identity.
Conclusion: Duty Above All
The Kamalesan verdict serves as a clear reaffirmation of the Indian Armed Forces’ core principle: when faith and duty clash, duty must prevail. By endorsing the dismissal, the Supreme Court has maintained the delicate balance that sustains the Army’s operational strength, in which personal beliefs give way to the collective need for unwavering unit cohesion.
This decision sends a strong message to all service members: the uniform demands full dedication to the regiment’s way of life, not just selective adherence, ensuring India’s soldiers stay united and capable of triumphing in any conflict. Ultimately, the spirit of discipline, tradition, and elan, built over generations, remains the true strength in battle, surpassing creed and protecting the nation’s sovereignty.