This article was written by Shubhangi Gandhi, a student of Rajiv Gandhi National University of Law, Punjab

Disclaimer : Please note that view expressed in this article are personal views of the author. Neither Racolb Legal nor the author wishes/intents to insult, harm or offend any religious or political sentiments.

CHAPTER 1: INTRODUCTION

India, the ancient land of cultures, traditions and virtues; where many a ruler came and brought with them a casket full of unique beliefs and worships. Just like a casket filled with various jewels, India is a casket filled with a plethora of jewels in the form of its religions and beliefs. Where in one corner lies the bright red ruby symbolising Hinduism, besides it also rests the jade stone symbolising the Islamic faiths. Similarly, the box is filled with sapphires, diamonds or gold coins symbolising the many more religions of the nation that exist together in one box i.e.- India. As said by Mark Twain, “India has 2 million gods, and they worship them all. In religion, all other countries are paupers, India is the only millionaire.” But such prosperity and richness in faiths do not come for granted. Every casket needs a strong lock to withhold all the ornaments inside it safe from outer mischief as well as protecting the baubles inside from falling out. Similarly, India also needed a lock to hold its richness within.  The framers of the Indian constitution recognised the need for such a security scheme clearly and hence introduced Articles 25-28. To safeguard the interests of people of all faiths and religions, the fundamental right to FREEDOM OF RELIGION was inculcated in the constitution of India. Such a fundamental right, even after 73 years of independence, has held together people of vast faiths together in one nation. According to statistical data, 94% of the world’s Hindus live in India with the world’s second-largest population of Muslims within a country behind only Indonesia. Additionally, there also are substantial populations of Muslims, Christians, Sikhs, Buddhists, Jains and adherents of folk religions. This makes India the most religiously diverse nation in the world. Moreover, to respect every religion existing in the territories of India, the nation holds no religion superior. Thus, in 1976 with a constitutional amendment the state of India was officially made a secular state (explained later in the article).

For most Indians, faith and religion guide them through their daily lives and hold utmost importance. According to a report, 8 in 10 Indians believe that religion and faith are necessary for their lives. When religion in India acts as a pillar of existence and guidance for the majority of the population, it goes without saying that it’s the dearest and sensitive topic for Indians. Majority of Indian history is filled with riots due to religious altercations and disagreements. Yet, the nation stands as one and united only due to Articles 25-28. This unique fundamental right of freedom of religion, upholding every religion equally and respecting them has enabled India throughout time to defeat all enemies of its integrity making it world’s largest democracy.

CHAPTER 2: EXPLAINING ARTICLES 25-28

Dalai Lama once said, “India has a great heritage and it is a model for religious harmony where people of different religions live peacefully and in harmony.”

The Indian constitution provides for 7 major fundamental rights that cannot be abridged by the state. These rights are highly protected and any encroachment of these rights are evaluated with strict scrutiny. Such rights are available to all citizens of India irrespective of their caste, creed, sex, place of birth, sex or any of them. Such rights are said to be universal rights accepted and recognised by the UN. One right among these 7 fundamental rights is of FREEDOM OF RELIGION.

The right to freedom of religion is a fundamental right guaranteed by the Indian constitution by articles 25-28.

Dating back to 3rd century BC, inscriptions of king Asoka show the plural nature of Indian society. These inscriptions said out loud and clear that the emperor honoured all sects with charity and respect. Approximately around 2nd century BCE, Emperor Kharvela declares himself in his inscription “a worshipper of all sects and a restorer of all shrines”. [1]

 Carrying forward these historical Indian values and culture of respecting all faiths, the constitution of India in Article 25-28 talks about freely professing, practising and promoting one’s faith peacefully.

2.1 ARTICLE 25

Article 25 of the Indian constitution guarantees freedom of conscience and free profession, practice and propagation of religion to all citizens of the nation. These freedoms come with added responsibility and are always a subject to public order and morality.
However, this article also provides for the state to make laws to A) regulate and restrict any financial, economic, political or other secular activity associated with any religious practice. B) provide for the social welfare and reform or opening up of Hindu religious institutions of a public character to all sections and classes of Hindus. (Under this provision, Hindus are construed as including the people professing the Sikh, Jain or Buddhist religions.)
For example, people of Sikh faith wearing turbans and carrying kirpans is considered as a profession of religion. In such cases, the challans for not wearing helmets for Sikhs wearing turbans were excused.

2.2 ARTICLE 26

This article provides the freedom to manage religious affairs with ease. It provides the right to form and maintain institutions for religious and charitable intents, manage its affairs in the matter of religion, acquire immovable and movable property and administer such property according to the law to every religious denomination. However, such freedom again is subject to morality, health and public order.

2.3 ARTICLE 27

This said article provides the freedom from payment of taxes for promotion of any particular religion.
According to Article 27 of the Constitution, there can be no taxes, the proceeds of which are directly used for the promotion and/or maintenance of any particular religion/religious denomination.

2.4 ARTICLE 28

This last article for the fundamental right of freedom of religion talks about Freedom as to attendance at religious instruction or religious worship in certain educational institutions. This particular article allows educational institutes maintained by certain religions to teach and spread their religious teachings, for example in the case of Madrasas. But this also implies that no religious instruction shall be provided in State-run educational institutions. And in cases of Educational institutions administered by the State but established under any trust which requires that religious instruction shall be imparted in such institutions is exempted from the above clause (that no religious instruction shall be provided).

According to this article for a person attending any educational institute run by the state, it is not compulsory to be a part or attend any religious worship being imparted in such institutions without consent.

CHAPTER 3: WHAT IS SECULARISM?

Secularism is that building block on which articles 25-28 stand. The whole concept of freedom of right to religion is what the concept of secularism is based on.

 The word “SECULAR” was added to the preamble and the basic structure of the Indian constitution by the 42nd amendment in 1976. The basic structure of the Indian constitution is technically immune to any amendments. All amendments are to be carried out keeping in mind the basic structure of the constitution. It is in a broad sense the basic framework or other words the skeleton of the constitution around which the other concepts of it are evolved and formulated.

 In its most basic sense, the word secular implies a separation from religion. To uphold the integrity and equality of every religion clear demarcation between a person’s belief and his motives for the nation must be made. If a person’s beliefs and faiths start to amalgamate with his motives for the nation, then that particular nation cannot have freedom of religion. In such cases, that person’s faith overshadows all other faiths and start to become superior. This depletes India of its democratic nature which is the supreme characteristic of the constitutions’ basic structure.

 Thus, secularism ensures that a separation of religion exists from the government, social, economic and cultural aspects of life. Here religion becomes an entirely personal matter and does not interfere in the growth of the nation.

 To summarise it, a secular state is a one with no religion. As stated earlier India as a nation has no national religion. Continuously repeated in articles such as Article 28, state-sponsored educational institutes are to not impart any religious teachings.

 (Here, state connotes the government of India or UOI)

 India, secularism, however, holds a unique additional meaning. In India secularism also inculcates and imparts equal respect for all religions and faiths. It is due to this that “at least on paper” all religious groups in India hold the same amount of powers without discrimination. Hence, festivals like Diwali (Hindu), Christmas (Christian), Eid (Muslim) and Guru Nanak’s birth anniversary (Sikh) take the form of national holidays within India.

CHAPTER 4: DOCTRINE OF BELIEF AND WHAT IS RELIGION?

The constitution of India uses the word “religion”, “religious denominations” and “belief” throughout sections 25-28. Where the fundamental right to freedom of religion completely relies on the meaning of these words and especially the word “religion”, the constitution has nowhere defined the word. Since no clear definition for the word “religion” is provided in the constitution, for the practical usage of the laws stated in sections 25-28, the courts faced 3 major issues.

1. A) As the constitution provides for high security for one’s religious beliefs and practices, it was imperative to define religion. This was necessary to understand which practices fell under the category of holding religious purviews and needed protection. B) The Court had to resolve the appeals against the legislation on the managing of religious institutions. C) Since these sections of the constitution provided autonomy and powers to religious denominations, it was also a challenge to draw a boundary of independence of such denominations.

 All such and other related issues hold a common ground; i.e. to identify a clear definition of the word “religion”. Such issues had to be tackled and a clear definition of the word be found. such was to battle the future demons of the constitution. All such powers and tenets needed to be struck down and removed which could be in dissent with the constitution and its principles.

 Religion is defined time and again in various subjects and purviews of human life. For example, in sociology religion is defined as “the beliefs, values, and practices related to sacred or spiritual concerns.”[2] In philosophy, “Religion is rational thought about religious issues and concerns without a presumption of the existence of a deity or reliance on acts of faith.” [3]

 To draw a similar framework for religion in the subject of law the courts devised the so-called “essential practice doctrine”. Such a doctrine distinguished between what was to be considered as religious matters and what shall be not.

The Indian courts, due to the diversity of religion in the nation, had a challenging time finding one perfect definition to fit all its vast religions. It even went on the look at US and Australian case-laws.

 The definition of religion given by the US court of laws in the case of Davis v. Beason 133 U.S. 333 (1890), was rejected by the Indian court. It negated the theory of calling only those practices religious where a relation was established between the individual and his gods and forms of worship. This was so because, in the Indian context, religious groups like Buddhists and Janis did not believe in a form of god or any other intelligent fist cause. Instead, the Indian court recalled what had influenced the drafting of articles 25 and 26 of the Indian constitution. The decision Adelaide Company of Jehovah’s Witnesses v. Commonwealth[4] of the Australian court recognised all practices done in pursuance of religious beliefs. Therefore, according to the Supreme Court of India, “rituals and observances, ceremonies and modes of worship are regarded as integral parts of religion” and religious denominations behaviours must be considered in order to ascertain the essential practices of their own religion, which are protected by the State until they do not infringe the limits provided by articles 25 and 26 of the Constitution.[5]

The definitions and the courts’ understanding of religion have been tested time and again throughout. The first time the “essential practice doctrine” was ever used was in the case of Shirur Mutt [6]in 1954. It was in this case that it was determined that the word “religion” shall also include in its ambit all rituals and practices that were “integral” to the religion. However, the court took the responsibility to decipher what was to be considered as an integral practice of religion, hence the doctrine was laid. Going further in 1983, the court finally laid down the principle with the aid of judicial precedent that “religion is a matter of faith. It is a matter of belief and doctrine. It concerns the conscience, i.e., the spirit of man. It must be capable of expression in word and deed, such as worship or ritual”. [7]This was by the case of SP Mittal v Union of India AIR 1983 SC 1.

CHAPTER 5: RELIGIOUS FREEDOM ISSUES

From the start of this article two things have been highlighted, 1) India is a secular state with diverse amalgamation of religions and 2) The Indian population consists 94% of global Hindu population.
Examining some of the data of The U.S. Commission on International Religious Freedom (USCIRF) since 2014 (The year since the inception of BJP rule in the Indian subcontinent).
The USCIRF report of 2014 said, “Despite the country’s status as a pluralistic, secular democracy, India has struggled to protect minority communities or provide justice when crimes occur due to a lack of political will, political corruption, and religious bias by government officials.” It placed India in tier 2 of religious freedom index where it had been since the year 2009.
Just 2 years later, in 2016, we see the already struggling freedom index deteriorating. In 2016, USCIRF writes in their report, “USCIRF will continue to monitor the situation closely during the year ahead to determine if India should be recommended to the U.S. State Department for designation as a “country of particular concern,” or CPC, under the International Religious Freedom Act (IRFA) for systematic, ongoing, egregious violations of religious freedom.”
In 2018, we see this US based organisation crying desperately, giving the Indian government another chance to reduce the ongoing miseries on religious minorities. It states in the report, “USCIRF again places India on its Tier 2 for engaging in or tolerating religious freedom violations that meet at least one of the elements of the “systematic, ongoing, egregious” standard for designation as a “country of particular concern,” or CPC, under the International Religious Freedom Act (IRFA).” Here in 2018 report we see the desperate efforts by the USCIRF in form of recommendations to the government to uphold India’s diversity. It even goes on to suggest a working out with the “MODI Administration” to create strategies for controlling hate crimes via the support of human and law ministries.
But in 2020, the USCIRF had had enough. With the enforcement of the citizenship amendment act (CAA), cow-slaughter laws and Babari-masjid dispute, an atmosphere of impunity was created in the nation. It was also noted that Mob lynching of persons suspected of cow slaughter or consuming beef continued, with most attacks occurring within BJP-ruled states. Therefore, highlighting that “In 2019, religious freedom conditions in India experienced a drastic turn downward, with religious minorities under increasing assault”; India was finally placed under the ambit of “Countries of Particular Concern” (CPC). The report even went on to point out clearly that “The national government allowed violence against minorities and their houses of worship to continue with impunity, and also engaged in and tolerated hate speech and incitement to violence.”

Any talks about religion sparks heated debates in the Indian subcontinent and rightly so. In a nation with more than 1.3 billion people and numerous faiths, a sensitive topic like religion has to spark debates. Whilst such scenarios prevailed in the country since the partition, the newly elected BJP government in 2014 pulled the religious freedom issues to new limelight. Drastic and dramatic changes have been made since 2014, which all coincidently benefitted one sect of the nation and discouraged a particular ethnic group only. Suddenly a nation that was moderately tolerant of others was now intolerant at every divergence. We see in reports that India continued to be in the organisation’s tier two of freedom index for 10 years (2009-2019), but gradual shifts in the tenure of a newly elected government led the nation to fall into a category that needed major amends.

To understand where exactly did things start to go wrong, let’s recall the concept of SECULARISM. As established earlier, the concept of secularism in its basic essence says that the state (i.e. the government essentially) to be separate from any religious leanings. The distinction between the state and religion shouts only one thing i.e. the government of the nation elected by the people and for the people, shall not have a religion of its own. Such was the concept to protect the principles of democracy in the country and uphold the divergent integrity of the nation within one boundary.

The Indian National Congress (INC) had been in power since independence. Due to such a long tenure of the government, the people of the nation started to recognise the small evils that had developed in the political system like corruption and black money. There is a saying “grass is always greener on the other side”. Due to a wave of needing a political change, the people of India went on to elect BJP in 2014. In the first 5- year tenure, the government is seen fighting the evils that the nation had been tired of. Suddenly there was a government standing up for the right. Whilst all this everyone overlooked the small changes that were taking place in the ideology of the country as a whole.

 The history of the party traces its origin in 1951 in collaboration with the Hindu nationalist Rashtriya Swayamsevak Sangh (National Volunteer Organization or RSS). In addition to this, BJP’s leader, Prime Minister Narendra Modi, is a self-avowed Hindu nationalist as well as a lifelong RSS member. While he was the chief minister of the state of Gujarat, he was accused of large-scale anti-Muslim rioting which left more than 1,000 people dead in 2002. According to reports, Modi was denied a U.S. visa under a rarely-used law barring entry for foreign government officials found to be complicit in severe violations of religious freedom in 2005. He also did not have any official contact with the US until 2013. All such reports and linking highlight the issue of India becoming a false secular state. It all points out the charade that the new government carried out to negate a secular India and get the nation to lose one of its most glorious characteristics. The hate that was planted 73 years ago with the unfortunate event of the partition, now spread like a wildfire burning the whole nation in forms of various riots, mob-lynching, forced conversions etc.

It has been pointed out by many US officials as well that violence over religious grounds has increased under the BJP government. What might have started as a wave of change has now taken the shape of the end of democracy with the government meddling with the basic structure of the constitution and considering above it.

CHAPTER 6: “HINDUTVA” AND SANGH PARIVAR

Various reports have shown the members of BJP associating themselves with the Rashtriya Swayamsevak Sangh also known as the “Sangh parivar”. Thus, to understand how this impacts the freedom of religion in India, it is needed to gain knowledge about the Sangh and its ideologies.
The Rashtriya Swayamsevak Sangh (RSS, or the ‘Sangh,’– literally ‘National Volunteer Corps’), was started in 1925 for ‘propagating Hindu culture.’ As an organization, the RSS is elusive and shadowy—it is only open to Hindu males – primarily upper caste; it maintains no smembership records; it has resisted being registered with the Government of India as a public/charitable trust; it has no bank accounts and pays no income tax.[8]

What led to the formation of this organisation was a conflict of ideologies between the father of the nation, Mohandas Karamchand Gandhi and a law student called Vinayak Damodar Savarkar. In 1906 Gandhi ji happened to stumble upon Savarkar in parts of Northern London in a student lodge. The latter was frying prawns which he offered to Gandhi. Gandhi being a vegetarian declined the offer from Savarkar much to his disappointment. According to him “Only a fool would attempt to resist the British without being fortified by animal protein”. The extent of truth that this story carries was never discovered but in the coming times, both the law scholars had conflicts about how the nation should be led to freedom. While Gandhi ji went on to become the leader of INC and the father of the nation, Savarkar went on to lead the Hindu Mahasabha. The hostilities between the two nationalists gave birth to two completely divergent groups. While Gandhi was a pacifist, he believed in the idea of an inclusive nation with diverse ideologies. But Savarkar’s belief was completely right leaning. He associated Indian identity with a Hindu identity and believed them to be inseparable.
Savarkar regarded Hindu as an ethnic, cultural and political identity. He considered the Indian subcontinent, which included the geographical area south of the Himalayas and the Hindu Kush, or “Akhand Bharat” as the homeland of the Hindus.[9]

Hindutva, is what the ideology of RSS is called. The RSS advocates a sort of Hindu patriotism, which endeavours to set up India as a Hindu Rashtra (Hindu Nation), and rejects the possibility of a composite Indian character achieved by a blend of various ethos and religions. The RSS indicates to be thorough of the entirety of the individuals who are racially and socially Hindu and places outside of the country every single one who stick to and relate to a substitute sureness or ethos, subsequently building up the opportunity of a Hindu Rashtra as a restrictive one where minorities may be in most ideal circumstances class 2 citizens. This specific perspective is contrastingly called a conviction plan of Hindu pride, Hindu vitality, Hindu fundamentalism, Hindu revivalism, Hindu chauvinism, Hindu zeal or Hindutva, subordinate upon who controls the definition. What is certain is the exclusionary and off the mark idea of the perspective. Many reports also use the terms hinduness or Hinduhood in place of Hindutva.

CHAPTER 7: CONCERNS

While in the broad spectrum it may seem that India is just facing challenges and struggling with religious freedom issues. However, if looked at it closely, there are several related concerns that follow. These concerns are so evil that they target the very being of India as a nation and the well being of its population.

7.1 GROWTH OF TYRANNY AND GOVERNMENT TERROR

As explained in the section of religious issues, what led to such issues in the nation was the change in the government. The ruling party’s open association with an organisation that was founded to support the beliefs of one faith definitely abridges the concept of secularism in the country.
According to the reports of USCIRF as stated earlier, cases of mob-lynching, forced conversions and an environment of hostility increased during the tenure of this government. As the government openly makes laws such as CAA, cow slaughter laws etc. supporting one religious sect, it sends across a clear message to other especially one particular religious minority that they are not equals. This forms a kind of a governmental tyranny in a nation where democracy and the principle of people being the deciding force was once the supreme factor.
Many labelled august 5^th 2020, as a red letter day in the political history of India, as “Prime Minister” Narendra Modi laid the foundation stone of the Ram Mandir on the much controversial land of Babri Masjid. What is wrong with this statement is the fact that the Prime Minister of the nation, a government official, a public servant; attends such a big event celebrating not the birth of a mandir but the destruction of a masjid in capacity of the post he holds. This clearly amalgamates the political persons faith and his duty towards the nation.
The increased mob lynching and public violence even the case of Jamia Milia Islamia, instils in the population seeds of fear of the government. Cases where activists were jailed without trail, send across a clear message from the government that No voice can be raised against it. Many have compared this with the Nazi Germany and no one can blame them.

7.2 SOCIAL MEDIA TRIALS AND SPREAD OF HATE

As the seeds of hate sowed during the partition by the British start to reap bitter fruits due the water given by BJP, two extreme groups have been formed. These two groups hold completely variant opinions which lead to social media wars on a regular basis. Threats over internet, usage of bitter language and abusive content is now a daily dose for any Indian social media user.
Such spread of hatred not only spoils the environment and makes the internet a toxic place, it also abridges the mechanisms of law. Where the reach of social media has become vast and fast, stories from across the globe reach any and everyone pretty soon. However, facts can be misused or concealed. Without knowing every fact and misled by planted proofs, groups over social media hold people guilty or not guilty of hate crimes or crimes against their religion. When courts are established and functioning properly in the nation, such trials just uproot the whole concept of law. The constitution of India was written in a span of 2 years 11 months and 18 days, with an expenditure of RS 6.4 million. All those years of hard work of a 284-member constituent assembly go down the drain with the increase of such social media trials.

7.3 ASSOCIATION OF RELIGION WITH NATIONALISM

One of the major principles propagated by the RSS was of Hindutva. An ideology which said that only the Hindu community where truly Indian. Such concepts were buried under the concept of a secular India. However, these concepts have again resurfaced in todays era. It seems like India is moving backwards in the progression scale.
In today’s India, if one does not show hate towards specific ethnical groups and a saffron support, they are put under the category of anti-national. Nationalism as a concept just speaks about love for ones’ own country, contrary to which it has now become love for a particular faith. Mixing up of these two concepts just drops India down many notches in the global front.

7.4 PSEUDO-SECULARISM AND DYING DEMOCRACY

Many so called “leftist” have coined a new term for today’s India- Pseudo secular. While India continues to be a secular state, with no official religion on paper, secularism is dying a slow death in the country. It can still be called somewhat secular because of the fact that under the purview of Hindus, Janis, Sikhs etc. have been inculcated. However, the organisation with which the government openly associates itself with has the agenda of making India a “Hindu Rashtra”.
As soon as the government started leaning towards a religion the concept of secularism was dead. As told about earlier, secularism is a basic feature of the constitution. Meddling with the basic structure of the constitution directly hits the democracy and the foundation stone of the constitution itself. The concept of secularism was brought into the constitution in 1976 via 42^nd amendment. However, the court in the ruling case of Shirur Mutt had said that secularism has always been a part and feature of Indian constitution.  As secularism dies a slow death, the death of democracy is guaranteed.

7.5       ALL OF INDIA AND DIGRESSION FROM REAL ISSUES

As the government’s prime focus remains religious issues and the conversion of a democratic state to an autocratic Hindu state, many major problems such as poverty, falling GDP, employment issues, infrastructure, international relations etc. are neglected. Most of these factors is what makes or breaks a country. There are real issues at hand other than the ethnicity and official religion of India. India being a secular state never had to question what its official religion is!
Such a question not only contaminates the mind of the Indian population as stated earlier, it also leads to the fall of a great nation.
As covid-19 strikes throughout the world, India is among the worst hit throughout the globe. With the vigorously falling GDP, no attention is being paid to it. What is called as the “Dirty Politics” also known as the vote bank politics, had digressed the nation’s attention from such real issues. These are the issues that need to be tackled and for which the government is chosen. If such issues are not dealt with soon, it might be the end a country which was destined to glory.

CHAPTER 8: CONCLUSION

The subcontinent of India has had a glorious past. A diverse range of cultures, ethnicities, values etc. that every Indian has been truly proud of. Many travellers from various foreign lands came and called India a land of colours and traditions. Such a glory cost India a unique constitution formed after studying various constitutions from across the globe. While elaborating on every minute detail and keeping in mind the vast ethnicity of the country, the framers of the constitution came up with articles 25-28. These articles took up the role of a security guard for protecting the basic fundamental right of religious freedom for Indian citizens.

 The partition of India during its independence in 1947 played a huge role in forming a gap between major ethnic groups in the country. Such a gap led to the formation of an entirely separate nation which is at war with India since its inception. It was the event of the partition that led to the addition of the articles 25-28 in the constitution. The intention of the framers was pure i.e. to leave no scope for in-country animosity or hate. But every security system always has one little loophole that malicious people misuse.

 What started as a diverse ethnic country, has turned into a massacre site for various faiths and their believers. This gradual shift from the nation of colours to a “Country of Particular Concern” for organisations following religious freedom in countries across the globe is linked to the new government of the country.

 As guards have fallen down and sections 25-28 of the constitution are under major threat, the sustainability of democracy in India becomes a big question. While its shown time and again that secularism and democratic principles are interlinked deeply, the death of one would lead to the death of the other. Mechanisms of law have been challenged and getting tried on a daily basis. The association of the ruling party of India openly with a religious organisation shouts that there is a leakage in the system of secularism in the country. While concerns of religious freedom top the charts many consequential issues also arise as a domino effect.

 While India faces such major challenges in the sphere of religion, it continues to strive for excellence in many other areas. A country so great should not have to worry about such petty issues. Major reforms, discussions and laws as suggested by USCIRF shall once again bring peace to the nation and uphold its integrity.

[1] religious conversion – a burning issue … is it dated back long back???, WORDPRESS (Dec. 21, 2014), https://upscforus.wordpress.com/2014/12/21/religious-conversion-a-burning-issue-is-it-dated-back-long-back/

[2] Chapter 15, RON MCGIVERN, INTRODUCTION TO SOCIOLOGY-1^ST CANADIAN EDITION.

[3] Section 3, PHILIP A. PECORRINO, PHILOSOPHY OF RELIGION (2001).

[4] HCA 12, (1943) 67 CLR 116.

[5] Valentina Rita Scotti, The “Essential Practice of Religion” Doctrine in India and its application in Pakistan and Malaysia, STATE , CHURCHES AND CONFESSIONAL PLURALISM, Feb. 8, 2016, at 5, 6.

[6] Endowments, Madras v. Shri Lakshmindra Thirtha Swamiar of Sirur Mutt , (1954) S.C.R. 1005 (India).

[7] S.P. Mittal Etc. Etc vs Union Of India, (1983) SCR (1) 729 (India).

[8] Hindutva: The Growth of Violent Hindu Nationalism, OUTLOOK, (Nov. 20, 2002), https://www.outlookindia.com/website/story/hindutva-the-growth-of-violent-hindu-nationalism/217969

[9] Hindutva and Sangh Parivar, SAAFBAAT, (Aug. 4, 2016), https://saafbaat.com/bjpsangh-parivar/hindutva-sangh-parivar