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Issues involved: Interpretation of Article 25 of the Constitution of India, relevance of charity and compassion in religious practices, validity of a provision preventing ill-considered death bequests under religious influence.
In this judgment, the Supreme Court analyzed the concept of charity and compassion in religious practices in the context of Article 25 of the Constitution of India. The court emphasized that while charity and compassion are preached in various religions, they may not necessarily constitute a part of religious practice as defined by the Constitution. The judgment highlighted that the encouragement of practicing charities for spiritual salvation, as seen in Christianity, is not a defining factor for religious practice. The court also drew parallels with teachings found in other religious texts such as Bhagavat Geeta and Upanishad to support this interpretation. Furthermore, the court referenced a previous case related to Islam to illustrate the broader understanding of religious concepts. The judgment discussed the meaning of "Islam" as "peace and submission" and emphasized the importance of submission to the will of God in its religious connotation. The court's analysis aimed to provide a comprehensive view of religious principles and practices across different faiths. Additionally, the judgment addressed a specific passage from the Gospel according to Luke, which the petitioners had quoted. The court noted that the Holy Bible published by Gideons did not contain the mentioned passage. Even if the passage was considered correct, the court interpreted it as advice given to an individual rather than a fundamental practice of the religion meant for the general populace. The court highlighted that teachings on renouncement from the world, as seen in the passage, do not necessarily align with the core tenets of Article 25 of the Constitution of India. Moreover, the court examined the impugned provision aimed at preventing individuals from making ill-considered death bequests under religious influence. The court observed that the legislative intent behind this provision was to safeguard illiterate or semi-literate individuals who blindly followed religious preachers. However, the court concluded that the purpose of the provision had lost significance over time and declared it ultra vires Article 14 of the Constitution of India. This decision reflected the court's commitment to upholding constitutional principles while interpreting and applying laws related to religious practices and influences.
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