Chhattisgarh High Court Upholds Gayatri Mantra Recitation in Government Schools, Says Constitution Does Not Ban Moral Instruction

Article 28(1) does not ban moral instruction disassociated from any denominational doctrines. — Chhattisgarh High Court

The Chhattisgarh High Court has dismissed a petition challenging the State Government's order directing government schools to include the Gayatri Mantra, Saraswati Vandana, Guru Mantra, Shanti Mantra, and other traditional prayers during school assemblies.

Justice Amitendra Kishore Prasad held that the petition was premature, observing that the government order does not compel students to participate against their religious beliefs or conscience. The Court further clarified that Article 28(1) of the Constitution does not prohibit moral instruction that is not linked to any particular religious denomination.

The Court granted liberty to the petitioners to approach it again if any actual violation of fundamental rights arises in the future.

What Does the Government Order Provide?

The controversy arose after the Chhattisgarh School Education Department issued an order dated June 12, 2026, prescribing activities to be conducted during daily school assemblies.

According to the order, schools are required to include:

At the beginning of the school day

• National Anthem

• National Song

• Deep Mantra

• Saraswati Vandana

• Guru Mantra

• Shanti Mantra

• Accounts of the lives of great personalities (Mahapurushas)

At the end of the school day

• Rajya Geet (State Song)

• Gayatri Mantra

• Shanti Mantra

The decision attracted political criticism, with the Opposition describing it as an attempt at the "saffronisation of education."

Petitioners Alleged Violation of Constitutional Rights

The petitioners challenged the government order by arguing that it violated several constitutional provisions, including:

• Article 14 – Right to Equality

• Article 21 – Right to Life and Personal Liberty

• Article 25 – Freedom of Religion

• Article 28(1) – Prohibition of religious instruction in educational institutions wholly maintained by State funds

• Article 29 – Protection of cultural and educational rights

• Article 30 – Rights of minorities to establish and administer educational institutions

According to the petitioners, students belonging to minority communities might feel compelled to participate in prayers that do not belong to their faith.

They further argued that reciting:

• Saraswati Vandana

• Gayatri Mantra

• Guru Mantra

• Shanti Mantra

amounts to imparting religious instruction and promoting a particular religion in government-funded schools.

The petitioners also contended that such directions were inconsistent with India's constitutional commitment to secularism.

State Defended the Policy

Opposing the petition, the State Government argued that the challenge was based on mere apprehensions and not on any actual injury or violation of rights.

The State submitted that the policy:

• Does not involve religious instruction.

• Does not promote religious conversion.

• Is consistent with the National Education Policy (NEP) 2020.

• Supports the integration of Indian Knowledge Systems (IKS) to promote cultural awareness.

The State further argued that the expressions "compulsory" and "ensure" used in the government order relate only to school administration and discipline and do not amount to religious coercion.

According to the State:

• No punishment or disciplinary action is prescribed for students who choose not to recite the prayers.

• The morning assembly aims to promote unity, discipline and concentration among students.

The State also described the traditional verses as ancient Indian philosophical texts promoting:

• Universal well-being

• Gratitude

• Ecological balance

• Intellectual development

The Gayatri Mantra, according to the State, is an invocation for wisdom and sharp intellect and is a scientifically and pedagogically beneficial cognitive exercise rather than religious propaganda.

High Court Finds No Coercion in Government Order

After hearing both sides, Justice Amitendra Kishore Prasad observed that the government order does not compel students to violate their religious beliefs.

The Court stated:

"A careful perusal of the impugned order dated 12.6.2026 reveals that it does not contain any mandatory or coercive direction compelling students to act in a manner contrary to their respective religious beliefs, conscience or faith."

The Court further noted that the petitioners failed to place any material on record demonstrating:

• Violation of any fundamental right.

• Any individual injury.

• Any direct harm caused by the government order.

Court Clarifies Meaning of Article 28(1)

One of the important issues before the Court was whether the prescribed prayers amounted to "religious instruction" prohibited under Article 28(1) of the Constitution.

Justice Prasad observed that the expression "religious instruction" has a limited scope.

According to the Court, Article 28(1) prohibits:

• Teaching religious customs.

• Religious rituals.

• Modes of worship.

• Religious practices.

in educational institutions wholly maintained by State funds.

However, the Court clarified that the Constitution does not prohibit moral instruction that is independent of denominational religious doctrines.

The judgment observed:

"Article 28(1) does not ban moral instruction, disassociated from any denominational doctrines, which remains an essential part of training in citizenship, maintenance of law and order in the State and growth of social cohesion."

Petition Dismissed as Premature

The High Court concluded that the petition was based entirely on apprehensions rather than any actual infringement of constitutional rights.

Finding no evidence of coercion or violation of religious freedom, the Court dismissed the petition.

However, it granted liberty to the petitioners to approach the Court again if any future circumstances give rise to an actual grievance.

Key Observations of the High Court

The judgment highlights several important legal findings:

• The government order does not compel students to act against their faith.

• No material was placed before the Court showing violation of any fundamental right.

• Article 28(1) prohibits religious instruction but not moral instruction unrelated to denominational doctrines.

• The prescribed prayers cannot automatically be treated as unconstitutional religious instruction.

• The petition was dismissed as premature because it was based on speculative concerns.

Case Details

Case Title: Abdul Salam Rizvi & Others v. State of Chhattisgarh & Others

Case Number: WPC No. 3372 of 2026

Court: Chhattisgarh High Court

Judge: Justice Amitendra Kishore Prasad