Supreme Court Upholds Dismissal of Army Officer Who Refused Temple Entry

The Supreme Court on Tuesday upheld the Delhi High Court’s decision to dismiss an Army officer who refused to enter the sanctum sanctorum of a temple during regimental duties, ruling that his actions amounted to disobedience and a breach of military discipline.

A bench comprising Chief Justice of India Surya Kant and Justice Joymalya Bagchi affirmed the termination of Army officer Samuel Kamalesan, observing that the Armed Forces operate on secular principles and that discipline within the institution cannot be compromised.

“What kind of message is he sending? He should have been thrown out for this alone. This is gross indiscipline by an Army official,” CJI Surya Kant remarked while declining to interfere with the High Court’s order.

Kamalesan had argued that being compelled to enter the inner sanctum violated his religious freedom as a Christian. The Supreme Court, however, held that his refusal constituted disobedience of a lawful command and impacted the cohesion essential to military functioning.

What the Delhi High Court Had Observed

In May, the Delhi High Court had upheld Kamalesan’s dismissal for repeatedly avoiding weekly regimental religious parades, despite counselling and several opportunities provided by his superiors. The court noted that the officer’s conduct—rather than his Annual Confidential Report (ACR)—had influenced the decision, as it adversely affected discipline and unit harmony.

The HC highlighted that the Armed Forces are “united by uniform, not divided by religion,” and that commanding officers bear a heightened responsibility to ensure the religious practices of all troops under their command are respected.

Kamalesan had claimed that while he accompanied personnel to the mandir and gurdwara during weekly parades and festivals, he sought exemption only from entering the temple’s sanctum sanctorum, citing his monotheistic Christian beliefs and sensitivity toward his troops’ sentiments. He also pointed out that the regiment had only a mandir and gurdwara, not a Sarv Dharm Sthal.

Who Is Samuel Kamalesan?

Commissioned as a lieutenant in March 2017, Kamalesan served in the 3rd Cavalry Regiment, which includes Sikh, Jat, and Rajput soldiers. He led a squadron composed primarily of Sikh personnel and highlighted the absence of a Sarv Dharm Sthal or church on the premises.

The Army maintained that Kamalesan frequently avoided mandatory regimental religious parades despite multiple attempts by senior officers to explain their significance. After reviewing his service record, the Chief of Army Staff concluded that his continued service was undesirable due to persistent misconduct.