New Delhi: The Supreme Court on Tuesday upheld the dismissal of Indian Army officer Samuel Kamalesan, a Christian officer who refused to enter the sanctum sanctorum of a temple during an official event. The court observed that the Army is a secular institution where discipline cannot be compromised, calling the officer’s conduct “gross indiscipline” and remarking that he was a “complete misfit for the Army.”
Kamalesan, commissioned as a Lieutenant in 2017 and posted with a Sikh squadron, had challenged the disciplinary action, arguing that he was compelled to act against his faith and that entering the temple violated his religious freedom. The court, however, held that his refusal amounted to disobedience of a lawful command.
A bench comprising Chief Justice of India (CJI) Surya Kant and Justice Joymalya Bagchi upheld a 2025 Delhi High Court order confirming Kamalesan’s dismissal from service without pension or gratuity in 2021. “You have hurt the feelings of your soldiers… this is the grossest kind of indiscipline,” CJI Surya Kant observed while declining to interfere with the High Court verdict.
What the Officer Argued
Senior Advocate Gopal Sankaranarayanan, appearing for Kamalesan, argued that the officer objected only to entering the temple’s sanctum sanctorum, stating it violated his personal faith. He maintained that Kamalesan had participated in events at Sarva Dharma Sthals and offered flowers from outside the temple but refused to enter the inner shrine. The defence claimed that disciplinary action was initiated by one superior officer despite no objections from others.
Sankaranarayanan argued that the Constitution protects an individual from being compelled to worship a deity, stating, “I cannot be forced to worship. The Constitution permits that freedom.”
Court Calls It Serious Indiscipline
The Supreme Court rejected the defence, questioning whether such behaviour was acceptable in a disciplined force. “Is this kind of cantankerous person acceptable in the Army? This exhibits the grossest kind of indiscipline,” the bench remarked.
The court also questioned whether the officer’s refusal amounted to disrespecting his own troops. “His own ego is so high that he won’t go with his soldiers… How can you refuse to enter?” the bench asked. The judges noted that a pastor had advised Kamalesan that entering the temple did not violate his faith, yet he still refused.
The bench stressed that military leadership demands leading by example. “You have failed to respect the sentiments of your own soldiers,” the court said, declining the officer’s plea for a reduced penalty.
