Why Supreme Court upheld dismissal of a Christian Army officer for refusing to enter gurdwara

The Supreme Court has upheld the dismissal of a Christian officer from the Indian Army for allegedly refusing to participate in religious rituals at his regiment’s temple and gurdwara. Describing him as a “misfit”, the top court backed the Army’s decision to terminate him in 2021.

A bench of Chief Justice Surya Kant and Justice Joymalya Bagchi declined to interfere with the Delhi High Court’s May order that had upheld the dismissal of Lieutenant Samuel Kamalesan. The officer had reportedly argued that participating in religious rituals went against his Christian beliefs.

Let’s take a closer look.

Why the Army removed a Christian officer

Commissioned in 2017, Samuel Kamalesan was posted with a Sikh squadron. As per a Bar and Bench report, he faced disciplinary proceedings for declining to enter the inner sanctum of the regiment’s Hindu temple and gurudwara during mandatory regimental parades.

Kamalesan claimed that his objection stemmed not only as a sign of respect for his Christian faith, but also out of respect for the sentiments of his troops, so as not to offend their religious sentiments with his non-participation in rituals.

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He also argued that his troops did not take offence, nor did it impact his strong bond with them, reported Bar and Bench.

The Army, however, said the officer refused to change his stance even after counselling by senior officers and Christian clergy. He was eventually terminated in 2021.

The Army said the officer’s objection undermined unit cohesion and troop morale.

In its May 30 order, the Delhi High Court upheld Kamalesan’s termination, saying the officer had kept his religion above a lawful command from a superior, which was “clearly an act of indiscipline”.

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It also noted that Section 41 of the Army Act makes disobeying the order of a superior officer an offence.

SC upholds Christian Army officer’s termination

The Supreme Court on Tuesday (November 25) upheld Kamalesan’s removal from the Indian Army.

A bench of Chief Justice of India (CJI) Surya Kant and Justice Joymala Bagchi said the officer’s actions were the “grossest kind of indiscipline by an army officer”.

Senior Advocate Gopal Sankaranarayanan, who appeared for Kamalesan, argued that the officer had committed only a “single infraction” by refusing to enter the sanctum at his place of posting.

“This one place in Punjab did not have a sarv dharm sthal (i.e., a structure symbolising the unity of all religions). It had a gurdwara…” he told the court.

“He is standing right outside the sanctorum. He told them, ‘Everything else you want me to do outside, I’ll do… but entering the sanctorum is against my faith…’,” Sankaranarayanan reportedly stated.

The advocate said only the commandant had a problem with Kamalesan’s refusal, not the other troops. Sankaranarayanan added that Kamalesan had no issue entering the Sarva Dharma Sthal.

“Entering the sanctum sanctorum is a violation of my faith… It’s not that when you join the Army, you lose the vestiges of your faith,” he said, adding, “No one had a problem. Only one person.”

However, the top court chided Kamalesan’s conduct.

“What kind of message is he sending? Gross indiscipline by an Army officer. He should have been terminated. This kind of cantankerous person deserves to be in the military?” the bench asked, as per NDTV. “He may be an outstanding officer but he is a misfit for the Indian Army. The amount of responsibilities our forces have at this time… this is not what we want to entertain,” the court added.

Supreme Court upholds dismissal of Christian Army officer for refusing to join regiment's religious rituals

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— Bar and Bench (@barandbench) November 25, 2025

Justice Bagchi noted that Kamalesan was counselled by a pastor who said there was no issue entering the sanctum sanctorum. “But then also he has his own personal interpretation. If the pastor, the head of your faith, says it does not affect the essential features of your faith, will the personal understanding of the believer be unique, or will the pastor’s view override?”

To this, Sankaranarayan said, “The conversation with the pastor was limited to the Sarva Dharma Sthal, not temple or gurdwara.”

“That’s the Sarva Dharma Sthal,” Justice Bagchi argued, but Sankaranarayan denied, as per Indian Express. 

CJI Kant said the leaders of troops must “lead by example”. “You are the group leader. In your team, there are Sikh soldiers, and because of them, there is a Sikh gurudwara… A gurudwara is one of the most secular places to visit. The tone and tenor and manner in which he is acting, is he not insulting his own soldiers?… We are surprised he doesn’t even follow the advice of the pastor,” he said.

Justice Bagchi also observed that Kamalesan had, in his reply, admitted that other Christian officers said “please do it, there is no difficulty”. “But your interpretation of your religious rights is ‘I am not going to offer flowers or havan in a gurudwara’. We understand that may be a sentiment of your understanding of your Christian faith. But that is not the essential features as appraised either by the pastor or other members of your faith.”

“Breach of Article 25 needs to be seen from the angle of essential features of the religion, not every sentiment of a religion… We have to definitely acknowledge and respect your essential features but you have to respect the collective faith of the majority of your command which you are commanding.”

The Supreme Court said it did not see “reason” to interfere with the Delhi HC’s verdict.

“We have heard the counsel for the petitioner at considerable length. We see no reason to interfere with the impugned judgment of the High Court order. The SLP is dismissed,” the bench was quoted as saying by Indian Express.

The apex court further said: “Army [is] completely secular in approach. You may do well elsewhere.. any constitutional provision with a grey area, we will look into it. You are guilty of violating … [Army Rules]. You have hurt the feelings of the soldiers.”

With inputs from agencies