Introduction
India’s constitutional architecture is unique in its dual commitment to protecting religious freedoms and upholding egalitarian values through constitutional morality.
In seeking to reconcile these sometimes conflicting imperatives—religious freedom and constitutional values—the Indian judiciary developed the Doctrine of Essential Religious Practices (ERP) in the early 1950s. Ostensibly intended to protect religious practices central to the faith while enabling State regulation of secular or extraneous aspects, the ERP doctrine has grown into one of the most controversial tools of constitutional adjudication in India. Over the decades, it has become both a gatekeeper for religious liberty and a lightning rod for criticism regarding judicial overreach and inconsistent application.
The significance of this doctrine came into sharp focus in two recent and widely discussed Supreme Court cases: Shayara Bano v. Union of India (2017), concerning the validity of instant triple talaq in Islam, and Indian Young Lawyers Association v. State of Kerala (2018), better known as the Sabarimala case, which dealt with the exclusion of menstruating women from entering the Sabarimala temple. In both cases, the Supreme Court was called upon not just to interpret constitutional provisions but to engage deeply with theological questions—whether a practice was essential to a religion and therefore deserving of constitutional protection. The contrasting opinions in both cases demonstrate the doctrinal instability of ERP and Its growing tension with the Constitution’s transformative aims.
Notably, the Constitution does not define what is “essential” to religion. The term is entirely a judicial invention, beginning with the Shirur Mutt case (1954), in which the Supreme Court held that courts could examine whether a particular religious practice was “essential” to a religion and thereby determine its constitutionality. This jurisprudential move was fraught with implications: it allowed secular courts to act as theological arbiters, a role traditionally disavowed in democratic and secular polities. The consequences of this judicial invention have become more problematic in recent years, as courts have had to evaluate practices deeply embedded in religious customs, even when these practices starkly conflict with values like gender equality, dignity, and non-discrimination.
As constitutional jurisprudence in India matures, a new set of legal and normative principles have begun to emerge—transformative constitutionalism, constitutional morality, and proportionality. These concepts offer a counter-narrative to the traditional ERP doctrine, one that prioritizes individual rights, dignity, and justice over rigid adherence to religious orthodoxy. In Sabarimala, Justice D.Y. Chandrachud’s invocation of transformative constitutionalism was emblematic of this shift. He argued that the Constitution must be interpreted in a manner that furthers liberty and dignity, not entrenches patriarchy or dogma.
The tension, however, remains unresolved. Shoul’ religious freedoms be curtailed when they conflict with equality and dignity? Who gets to decide what is central to a religion—the courts, religious institutions, or individual believers? Is the judiciary competent or even constitutionally authorised to make theological determinations? And is the ERP doctrine structurally majoritarian in the way it favours familiar, codified practices over oral and minority traditions?
This article seeks to answer these pressing questions by revisiting the origins, evolution, and implications of the ERP doctrine in Indian constitutional law. It argues that the doctrine, while perhaps useful in its original context, has now become inconsistent with both the spirit and letter of India’s constitutional morality. Through a critical analysis of judicial decisions, comparative constitutional insights, and theoretical foundations, the article ultimately contends that the ERP doctrine should be replaced by a proportionality-based framework that aligns better with democratic values, individual rights, and the secular character of the Indian State.
Evolution and Development of the Essential Religious Practices Doctrine
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The Genesis: Shirur Mutt and the Judicial Construction of ERP
The doctrine of Essential Religious Practices (ERP) was first introduced by the Supreme Court in The Commissioner, Hindu Religious Endowments, Madras v. Sri Lakshmindra Thirtha Swamiar of Shirur Mutt, where the Court held that Article 25 protected not just beliefs but also rituals integral to religion.¹ However, the Court assumed the power to determine which practices were “essential,” placing secular judges in the role of theological arbiters—a role not envisioned by the Constitution.
This judgment, while seemingly protective of religious freedom, created a contradiction within secularism. It empowered the judiciary to interpret what is essential to a religion without offering clear criteria or procedural safeguards.² The result was a subjective, and often inconsistent, application of the doctrine that shaped future jurisprudence in ways both progressive and problematic.
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Expansion, Manipulation, and Dilution of ERP in Subsequent Jurisprudence
In Durgah Committee, Ajmer v. Syed Hussain Ali, the Supreme Court held that only essential practices consistent with constitutional morality were protected, excluding “superstitious beliefs.”³ This judgment further entrenched the judiciary’s discretion to draw subjective lines between religion and superstition, often using rationality as a benchmark.
Later decisions reflected the same discretionary power. In Seshammal v. State of Tamil Nadu, the Court upheld the State’s right to regulate the appointment of temple priests, holding that hereditary succession was not essential to the Hindu religion.⁴ Similarly, in Ismail Faruqui v. Union of India, the Court controversially held that a mosque is not an essential part of Islamic practice for offering prayers.⁵
The case of Ananda Marga v. State of West Bengal saw the Supreme Court declare that the tandava dance, a public religious ritual, was not essential to the Ananda Marga faith, despite religious evidence to the contrary.⁶ This selective skepticism, especially toward minority sects, revealed the majoritarian undertone within ERP jurisprudence.
Thus, while ERP began as a protective doctrine, it evolved into a tool of exclusion—often applied more stringently to minority or lesser-known sects. The essentiality test became unpredictable, lacking a clear methodology. Religious liberty, therefore, came to depend not on the text of the Constitution but on judicial perceptions of religiosity.
Key Judicial Applications of the Essential Religious Practices Doctrine
The application of the ERP doctrine in Indian constitutional jurisprudence has been inconsistent, fragmented, and context-driven. Over time, the Supreme Court has approached religious practices with varying degrees of deference, often driven by ideological, political, and societal influences. The following key decisions—each a landmark in its own right—highlight the doctrine’s evolution and internal contradictions.
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Bijoe Emmanuel v. State of Kerala (1986): Constitutional Deference over Essentiality
In Bijoe Emmanuel, three Jehovah’s Witness students were expelled from school for refusing to sing the national anthem, despite standing in respectful silence.¹ The Kerala High Court had ruled that such refusal constituted disrespect and was not protected under Article 25. The Supreme Court overturned this decision and held that freedom of conscience and belief—even if considered irrational or minority-held—deserves constitutional protection.
Crucially, the Court did not apply the ERP test. Instead, it placed emphasis on the sincerity of belief rather than its essentiality to the religion. Justice O. Chinnappa Reddy observed that what is protected is not only orthodox or mainstream belief, but any belief genuinely held.² This judgment is celebrated for giving primacy to individual autonomy in matters of faith and serves as a benchmark for a liberal, rights-based understanding of religious freedom.
The decision stands out precisely because the Court resisted the temptation to engage in theological analysis. It showed that the Constitution does not require the judiciary to validate religious doctrines but only to verify that a belief is genuinely held and not in conflict with public order, health, or morality.
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Shayara Bano v. Union of India (2017): Triple Talaq and the Fragmented ERP Reasoning
Shayara Bano was a landmark case that examined the validity of talaq-e-biddat, the practice of instant triple talaq in Islam. The case involved a constitutional challenge to the practice on the grounds that it violated women’s dignity, equality, and personal liberty under Articles 14, 15, and 21.
The five-judge bench delivered a split verdict. Three judges invalidated the practice, but with differing justifications. Justices Nariman and Lalit held that instant triple talaq violated constitutional guarantees of equality and non-arbitrariness, thereby making it void under Article 14.³ Justice Kurian Joseph, however, adopted an ERP approach and ruled that talaq-e-biddat was not essential to Islam and hence not constitutionally protected.
This divergence revealed a core inconsistency: Was the practice struck down because it was un-Islamic, or because it was unconstitutional? The former approach relies on theological judgment; the latter on constitutional reasoning. By allowing both rationales to coexist without hierarchy, the Court blurred the line between secular adjudication and religious interpretation.
This case underscores the doctrinal confusion that results from deploying ERP alongside constitutional tests. It also demonstrates how ERP, while intended to protect religion, often functions to invalidate religious practices when the Court finds them incompatible with modern sensibilities or liberal constitutional values.
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Indian Young Lawyers Association v. State of Kerala (2018): Sabarimala and Gender Justice
The Sabarimala case involved a centuries-old practice barring women aged 10–50 from entering the temple of Lord Ayyappa. The temple’s management argued that the exclusion was an essential religious practice of the denomination, grounded in the deity’s celibate nature.
A 4:1 majority of the Supreme Court struck down the ban, holding that it violated Articles 14, 15, and 25.⁴ The majority ruled that the exclusion of women was not essential to the religion and that the temple, as a public religious institution, could not discriminate on the basis of sex. Justice D.Y. Chandrachud’s concurring opinion advanced the idea of transformative constitutionalism—interpreting the Constitution as a tool for social change rather than status quo preservation.
Once again, the Court’s primary tool of analysis was the ERP test. The majority held that since celibacy is a personal vow and not a constitutional justification for exclusion, the practice could not be protected. But the dissent by Justice Indu Malhotra highlighted a crucial concern: courts are ill-equipped to decide theological questions. She warned against judicial intervention in deeply held religious beliefs, arguing that ERP had to be interpreted from within the faith, not from a constitutional bench.
The case exposed the philosophical divide within the judiciary. On one side stood transformative justice and gender equality; on the other, autonomy of religious denominations. It is telling that the matter is now pending reconsideration by a larger bench, demonstrating the unresolved tension between gender rights and religious autonomy under the ERP framework.
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Ananda Marga v. State of West Bengal (2004): Rituals and the Limits of ERP
In this case, the religious order Ananda Marga challenged a state ban on performing the tandava dance in public processions, claiming it was an essential religious ritual. The Court held that the dance was not an essential practice and upheld the ban.⁵
Notably, this contradicted an earlier judgment in 1983 which had upheld the same dance as essential. The reversal without significant doctrinal justification highlighted the inconsistency of ERP determinations. The Court also relied more on public perception than internal religious doctrine—a trend that marginalizes non-mainstream and minority sects.
Key Observations from Case Law
- Subjectivity: Courts use varying criteria (scripture, tradition, perception) to determine essentiality.
- Fragmentation: There is no consistent jurisprudential hierarchy between ERP and constitutional rights.
- Majoritarianism: Minority and sectarian practices are more often deemed non-essential.
- Judicial Theology: Judges often assume interpretative roles reserved for religious authorities.
The Essential Religious Practices (ERP) doctrine, though formulated to balance religious freedom with constitutional limitations, has over the decades come under increasing scrutiny. Critics argue that it fosters judicial overreach, suffers from doctrinal inconsistency, undermines the transformative goals of the Constitution, and may in fact enable majoritarianism under the guise of neutrality. This section analyses these critiques in detail, exposing how the ERP doctrine often fails to uphold the very principles it was designed to protect.
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Judicial Overreach into Theological Domains
The Indian Constitution adopts a model of principled secularism—one that does not mandate a wall of separation between religion and State, but envisions equidistance from all faiths. However, ERP compels the judiciary to act as a theological authority, a role fundamentally at odds with this vision.
By asking courts to determine what is “essential” to a religion, ERP assumes that secular judges—often without theological training—can adjudicate religious doctrine. This raises serious concerns regarding institutional competence. In cases such as Sabarimala and Ananda Marga, the courts have passed verdicts on religious practices by interpreting scriptures, religious texts, or traditions—a task that should ideally rest with the community of believers or religious scholars.¹
This judicial appropriation of theological space also contradicts the autonomy granted under Article 26(b), which allows religious denominations to manage their own affairs in matters of religion. If the judiciary can negate religious claims by declaring them non-essential, then the very right to religious self-determination is hollowed out.
Moreover, ERP violates a basic constitutional precept: that fundamental rights are individually held. A person’s right to religious belief and practice should not hinge on whether the court deems it essential. What matters is sincerity, not essentiality—a principle better reflected in Bijoe Emmanuel, where the Court upheld a minority religious belief without invoking ERP.
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Inconsistency and Absence of Jurisprudential Standards
A core flaw of the ERP doctrine is its lack of uniform application. Different benches have applied different criteria—sometimes relying on scriptures, sometimes on historical practice, and at other times on judicial precedent. The absence of a consistent methodology leads to arbitrary outcomes, undermining the predictability of constitutional adjudication.
For instance, in Ananda Marga (1983), the Court upheld tandava as essential, but in 2004, reversed this position with no clear change in reasoning or context.² Similarly, in Shayara Bano, three judges gave three different rationales: theological (Joseph, ERP), constitutional (Nariman and Lalit, Art. 14), and procedural (Khehar and Nazeer, deferring to Parliament). This doctrinal confusion diminishes clarity and fuels unpredictability in how religious freedom is adjudicated.
The problem is compounded by the absence of doctrinal tools to distinguish “core” from “peripheral” practices. In a diverse religious landscape like India—where most traditions are layered, non-textual, and transmitted orally—ERP disproportionately privileges practices backed by scriptural authority. Oral traditions, local customs, and reformist sects often find themselves excluded from constitutional protection.
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Conflict with Transformative Constitutionalism and Gender Justice
India’s Constitution is not a static document. It envisions a transformative project aimed at dismantling entrenched hierarchies and advancing liberty, equality, and dignity. ERP, however, often inhibits transformation by preserving discriminatory practices simply because they are religious.
In Sabarimala, the majority of the Court applied ERP to strike down the women’s entry ban, but also invoked constitutional morality and gender justice. Justice D.Y. Chandrachud’s opinion stressed that religious practices, however longstanding, must yield to fundamental rights if they infringe upon dignity and equality.³ This marks a shift from protecting religion to scrutinising it in light of constitutional values.
However, ERP remains incompatible with this shift. By focusing on whether a practice is “essential” rather than whether it harms or violates rights, the doctrine allows regressive practices to be shielded if they are deemed core to the religion. In this way, ERP can be used to protect patriarchal or caste-based exclusions, frustrating the Constitution’s egalitarian aims.
Moreover, ERP treats religion as monolithic—as though each faith has a single, internally coherent view of what is essential. In truth, religious communities are diverse, evolving, and contested spaces. Feminist and anti-caste critiques from within religious traditions often challenge dominant interpretations, demanding reform from inside. ERP, by freezing religion into static categories, silences these progressive voices.
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Majoritarian Bias and Marginalisation of Minority Faiths
Another severe criticism of ERP is that it tends to operate with an implicit majoritarian bias. Practices of dominant faiths—particularly codified or Vedic Hinduism—are more likely to be accepted as essential, while those of minorities or non-mainstream sects are more readily dismissed. This creates a hierarchy of religiosity, where dominant traditions are normalized and minority expressions are delegitimized.
For example, the ban on tandava in Ananda Marga was upheld despite internal doctrinal support, whereas similar Hindu rituals involving dance and public procession have rarely faced such scrutiny.⁴ In Ismail Faruqui, the Court controversially ruled that offering prayers in a mosque is not essential to Islam—despite overwhelming theological evidence to the contrary.⁵ These cases show how ERP can reinforce dominant cultural assumptions under the pretext of legal neutrality.
This doctrinal selectivity undermines pluralism, a cornerstone of Indian secularism. It leads to a “one-size-fits-all” approach to religion, marginalising communities that practice faith in non-canonical or oral forms. It also discourages religious reform, because any deviation from the judicially approved version of religion risks being declared non-essential.
In recent years, legal scholars and progressive jurists have advocated moving away from the Essential Religious Practices (ERP) doctrine toward the doctrine of proportionality—a structured, rights-based test that better aligns with India’s constitutional ethos. Proportionality offers a more consistent, principled, and democratic framework to evaluate conflicts between religious freedom and other fundamental rights, particularly those concerning equality, dignity, and liberty.
Understanding Proportionality in Constitutional Law
The doctrine of proportionality is well-established in comparative constitutional jurisprudence, especially in jurisdictions like Germany, South Africa, Canada, and the European Court of Human Rights. It involves a four-step test:
- Legitimate Aim: Is the objective of the restriction valid under constitutional standards?
- Suitability: Is the measure adopted suitable to achieve that aim?
- Necessity: Is the measure the least restrictive way to achieve the goal?
- Balancing: Do the benefits of the restriction outweigh the harm to fundamental rights?
The Indian Supreme Court formally adopted proportionality in Modern Dental College v. State of Madhya Pradesh (2016), and reaffirmed it in K.S. Puttaswamy v. Union of India (Privacy case) (2017).¹ These decisions emphasised that limitations on rights must be justified through structured reasoning, not vague claims of morality or public interest.
Why Proportionality Is Preferable to ERP
The ERP doctrine asks whether a religious practice is essential to a faith. If deemed non-essential, it can be regulated or prohibited without triggering further constitutional analysis. But this test is binary and theological—it does not evaluate whether restricting a practice infringes rights or whether the restriction is justified.
Proportionality, on the other hand, shifts the focus from what religion demands to what the Constitution protects. It acknowledges that even essential religious practices may sometimes conflict with other constitutional values—but such conflicts must be resolved through careful balancing, not theological disqualification. This makes proportionality:
- Rights-focused, not religion-focused
- Context-sensitive, not absolutist
- Procedurally fair, allowing both sides to be weighed
Moreover, proportionality avoids the jurisdictional overreach that ERP involves. Judges are not required to interpret scriptures or decide what is theologically core. They only need to assess whether a restriction on a religious practice is constitutionally justified, using rational and transparent criteria.
Application of Proportionality in Religion-Related Cases
Although the Indian judiciary still largely uses ERP in religious freedom cases, there have been some promising moves toward proportionality.
In the Sabarimala case, Justice D.Y. Chandrachud invoked proportionality when arguing that exclusion of women violated dignity and autonomy. He noted that any practice that discriminates on the basis of sex must pass a rigorous constitutional test, including proportionality.² Though the majority relied more on ERP, his concurring judgment provided a roadmap for future rights-based reasoning.
Similarly, in Puttaswamy, the Court stressed that religious norms must yield to individual autonomy and dignity when there is a conflict. While not directly about religion, the ruling established that State actions and social practices must satisfy constitutional scrutiny, especially when they infringe privacy or liberty.
Proportionality has also been endorsed in academic literature. Scholars such as Suhrith Parthasarathy and Arvind Narrain argue that it creates a normative bridge between competing rights claims—between group rights and individual rights, between tradition and change.³
International Precedents Supporting Proportionality
Globally, courts have successfully applied proportionality in religious freedom cases. The European Court of Human Rights (ECtHR), for example, has repeatedly used proportionality to assess whether restrictions on religious symbols or attire are justified.
In Leyla Sahin v. Turkey (2005), the ECtHR upheld a ban on headscarves in universities, stating that the restriction was proportionate to the aim of secularism.⁴ Though controversial, the judgment showed that even essential religious practices can be limited—but only after structured justification.
In Canada, the Supreme Court in Multani v. Commission scolaire Marguerite-Bourgeoys (2006) held that banning a Sikh student from wearing a kirpan (a ceremonial dagger) was unconstitutional. The Court ruled that the restriction was not proportionate, as it failed the minimal impairment test.⁵
These examples show that proportionality allows nuanced, pluralist adjudication—where courts do not negate religious practices outright, but examine whether limitations are truly necessary and proportionate.
Challenges in Implementing Proportionality in India
While proportionality offers a promising alternative, it is not free from challenges. First, it requires judicial discipline and transparency. Courts must apply each stage of the test rigorously, rather than invoking proportionality as a rhetorical label.
Second, proportionality presumes a rights culture—one where both State and society take constitutional rights seriously. In India, where religion plays a dominant public role and rights literacy is low, enforcing such a framework may face institutional resistance.
Third, in deeply polarised contexts, even proportionality may be perceived as hostile to religion, especially if it results in invalidating long-standing traditions. Therefore, courts must combine proportionality with sensitivity and deliberative engagement, including consultation with affected communities.
Yet, these challenges are manageable, especially when compared to the problems ERP creates—doctrinal confusion, judicial overreach, and rights suppression.
Conclusion
The Essential Religious Practices (ERP) doctrine, introduced as a judicial safeguard for religious autonomy, has over time evolved into a double-edged tool. While intended to delineate constitutionally protected practices from those that may be regulated, ERP has increasingly served as a mechanism for judicial intrusion into matters of faith. The doctrine has lacked consistent standards, been deployed inconsistently, and often tilted toward majoritarian understandings of religion.
Its binary framework—declaring a practice either essential and therefore protected, or non-essential and therefore regulable—fails to do justice to the pluralism and dynamism of Indian religious life. ERP assumes that religions are monolithic, static, and hierarchically organized, with clear “essential” cores—an assumption that is far removed from the lived reality of many faiths in India, particularly those based on oral traditions, local customs, or evolving interpretations.
Further, ERP has at times allowed regressive social practices to be upheld simply because they were declared “essential,” while suppressing internal movements for reform. It has also enabled the State and judiciary to favor certain religious narratives, inadvertently promoting religious homogenization at the expense of minority expressions.
In contrast, the doctrine of proportionality offers a more constitutionally sound alternative. It respects the individual’s right to religion, assesses whether any restriction is justified through a structured framework, and aligns judicial review with the transformative promise of the Indian Constitution. It does not ask whether a practice is “essential” to a religion; instead, it asks whether limiting that practice is necessary and proportionate to uphold other constitutional goals—like dignity, equality, or public order.
The shift to proportionality would also reframe Indian secularism as rights-based rather than religion-based, focusing on protecting individuals rather than arbitrating religious truths. This transformation is critical if India is to remain committed to both religious freedom and social justice.
Moving forward, the following recommendations may guide judicial reform:
- Judicial restraint in theological matters: Courts should avoid interpreting scriptures or determining religious orthodoxy.
- Adoption of proportionality as the primary test in Article 25 and 26 cases, particularly where fundamental rights like equality, dignity, and liberty are at stake.
- Institutional clarity: Constitutional benches should definitively pronounce on the status of ERP and whether it should be subsumed or replaced by proportionality.
- Recognition of internal religious pluralism: The judiciary must acknowledge diversity within faiths, allowing space for dissenting and reformist interpretations.
- Procedural fairness and dialogue: Before restricting a religious practice, affected communities should be heard and their perspectives considered in detail.
The Supreme Court is presently re-examining ERP in several pending matters, including the Sabarimala review and questions referred to a larger bench in cases concerning religious denominations and gender rights. This is an opportune moment for the judiciary to introspect and evolve beyond the ERP framework.
In conclusion, religious freedom in India must not hinge on whether a practice is ancient or scripturally validated. It must depend on whether the practice respects human dignity, promotes social harmony, and upholds the transformative values enshrined in the Constitution. For that, ERP must yield to proportionality.
End Notes:
Section 1
- Raju Ramachandran, ‘Judicial Theology and Religious Freedom’ (2005) 17(2) NLSIR 123.
- Commissioner of Police v Acharya Jagadishwarananda Avadhuta (2004) 12 SCC 770.
- Indian Young Lawyers Association v State of Kerala (2018) 10 SCC 1.
- Pritam Baruah, ‘Interpreting Religious Freedom in India: Essays in Constitutional Morality’ (2020) 5(1) Indian Law Review 15.
- Ismail Faruqui v Union of India (1994) 6 SCC 360.
- Proportionality: A Better Alternative to the Essential Religious Practices Doctrine
Section 2
- Bijoe Emmanuel v State of Kerala AIR 1987 SC 748.
- Gautam Bhatia, Offend, Shock, or Disturb: Free Speech Under the Indian Constitution (OUP 2016) 195.
- Shayara Bano v Union of India (2017) 9 SCC 1.
- Indian Young Lawyers Association v State of Kerala (2018) 10 SCC 1.
- Commissioner of Police v Acharya Jagadishwarananda Avadhuta (2004) 12 SCC 770.
- Constitutional Critique of the Essential Religious Practices Doctrine
- The Commissioner, Hindu Religious Endowments, Madras v Sri Lakshmindra Thirtha Swamiar of Shirur Mutt AIR 1954 SC 282.
- Durgah Committee, Ajmer v Syed Hussain Ali AIR 1961 SC 1402.
- Raju Ramachandran, ‘Judicial Theology and Religious Freedom’ (2005) 17(2) NLSIR 123.
- Commissioner of Police v Acharya Jagadishwarananda Avadhuta (2004) 12 SCC 770.
Section 3
- Modern Dental College v State of Madhya Pradesh (2016) 7 SCC 353; K.S. Puttaswamy v Union of India (2017) 10 SCC 1.
- Indian Young Lawyers Association v State of Kerala (2018) 10 SCC 1, concurring opinion of Chandrachud J.
- Suhrith Parthasarathy, ‘Beyond Essential Practices: Towards a Proportionality Review’ (2018) 13(2) NUJS L Rev 1.
- Leyla Sahin v Turkey (2005) ECHR 819.
- Multani v Commission scolaire Marguerite-Bourgeoys [2006] 1 SCR 256 (Canada).
Section 4
- Rajeev Dhavan, ‘Religious Freedom in India’ (2001) 6(2) Asia-Pacific Journal on Human Rights and the Law 25.
- Bindu Dalmia, ‘Why Essential Religious Practices Doctrine Must Be Reviewed’ The Hindu (Chennai, 10 October 2018).
- Arvind Narrain, ‘The Transformative Constitution and Religious Freedom’ (2019) 14(1) NUJS L Rev 45.
