Lieutenant Samuel Kamalesan dismissal upheld by Supreme Court

In November 2025, the Supreme Court upheld the dismissal of Army officer and troop leader Lieutenant Samuel Kamalesan, a Protestant Christian, after he refused to enter the sanctum of his regiment’s temple and a gurudwara.

Previously in May 2025, the Delhi High Court had terminated the officer’s tenure, stating that he could not opt out of regimental practices. Samuel, who had consistently attended the troops’ religious parades and shown respect toward other faiths, declined to enter the sanctum sanctorum of a temple and a gurudwara, citing his personal faith and beliefs.

The Court’s decision was anchored in Article 33 of the Indian Constitution, which allows the restriction of fundamental rights of armed forces personnel in the interest of maintaining discipline and ensuring the proper discharge of duties. This legal provision was used to justify requiring all regimental members to participate in ceremonial practices considered part of the military ethos.

The bench, led by Chief Justice Surya Kant, emphasised that while individual beliefs are acknowledged, uniformity and cohesion in military practices are paramount, given the nature of military operations.

The Court ruled Samuel a misfit and described him as a cantankerous man, stating that his refusal amounted to a disregard for military ethos. In India, every military base and residential area has designated places of worship for different religions, with pandits, priests, maulvis, and monks appointed and paid by the Defence Ministry.

With the Supreme Court upholding the Delhi High Court’s verdict, the dismissal of an Army officer who stood by his personal beliefs has now been legally affirmed.

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