Thursday, May 7, 2020

Bhagwa Patāka & Police

In A.S. Narayana Deekshitulu vs. State of Andhra Pradesh (AIR 1997 SC 3702), the Honourable Supreme Court defined Dharma as -
Sarblok Priyo Nityamubachaidahar Nisham
Nandantu Sarb Bhutani Snidyantu Vijanepwapi
Swastyastu Sarb Bhurtesu Nirantakani Santu cha
Ma Vyadhirastu Bhutanamadhyon Bhawantu cha
Maitrimashesh Bhutani Tushyantu Sakle Jane
Shibmastu Dwijatinam Pritirastu Parasparam.


The learned apex court was quoting from Chapter 188 (Verse 12-17) of the Markandeya Purana. It went on to preach that expressing the purpose of Dharma is that all persons may be happy, may express each other's happiness, that there may be the welfare of all, all being free from fear and disease; cherish good feelings and sense of brotherhood, unity and friendship. It looks all hunky-dory until we ask a simple but beguiling question - Why is the learned Supreme Court preaching Dharma to Hindus? After all, it is a temple of justice, not a temple of gods. For a court of law to describe a man’s faith to him, is to unilaterally disparage his religion in at least two distinct ways: by describing, and by characterizing. It is an authority a democratic government must not possess.


Such forced constitutional morality must be seen as a transgression. It seems the legal system prioritises its perceived morality over the sea of masses or even individual assertions, which is disturbing because in the case Navtej Singh Johar and Ors. vs. Union of India (UOI) and Ors. (2018 10 SCC 1), the learned apex court explained that constitutional morality requires in a democracy the assurance of certain minimum rights, which are essential for free existence to every member of the society for both individual and communal living. Constitutional morality cannot be nurtured unless, as recognised by the Preamble, there exists fraternity. In the US, Thomas Jefferson gave the battle cry "all men are born equal and they are endowed with the inalienable rights of life and liberty and pursuit of happiness". When the French soldiers fought the revolution barefooted, they had the battle cry, 'liberty, equality and fraternity'. Some jurists have said that there is hardly a sovereign, democratic, republic constitution preamble of this character, but it is imperative for a fraternity to exist that it provides everyone’s conscience liberty and equality.


If people who agree with certain beliefs or loyalties or both are the only ones allowed to have liberties such as those of speech and expression, faith, trade etc, the concept of equality becomes null and void. On 26th of April, Bihar Police booked some Bajrang Dal men for installing saffron flags (Patāka) at Hindu shops and vends. The FIR alleged that they were requesting passersby Hindus to purchase stuff from those shops which had saffron flags or were owned by Hindus (CN 147/2020, Laheri PS, Nalanda). They were booked under IPC sections 147, 149, 188, 153A, 295A and Section 66 of the IT Act. The complaint was made via a social media platform - Twitter.


It is difficult to understand how simple community strengthening exercises like installation of saffron-coloured flags at Hindu proprietorships that too done with prior consent and blessings of the proprietors, and gently requesting buyers to buy from these particular shops can be painted as an attack on communal harmony in view of disability, race, creed, colour, sex, sexual orientation, marital status, national origin, or ancestry. Section 147 of the IPC is for rioting but the men were merely putting up flags with consent and cooperation of the vendors after a Ram Navami procession was withheld because of the Chinese virus led lockdown. Section 149 is for unlawful assembly guilty of an offence committed in prosecution of a common object. The 'offence' comprised of simply putting up Hindu flags. Section 188 is for disobedience to order duly promulgated by a public servant which is justifiable considering they were out doing the 'offence' during Coronvirus pandemic led government-imposed lockdown. Section 153A is for promoting enmity between different groups on grounds of religion but the police failed to discern how the installation of the said flags was promoting enmity and between which communities.


Section 295A is for deliberate and malicious acts, intended to outrage religious feelings of any class by insulting its religion or religious beliefs. It is tough to comprehend how the installation of flags by Hindu vendors in their private stalls or shops is a deliberate malicious act towards any religion's or the government's beliefs. It appears that Bihar Police has suddenly found religion. Constitution commits government itself to religious tolerance, and upon even slight suspicion that proposals for state intervention stem from animosity to religion or distrust of its practices, all officials must pause to remember their own high duty to the constitution and to the rights it secures.


Such conundrums are not limited to India. In 2007, the airport commission of the Twin Cities of Minneapolis–Saint Paul was peeved at Somali Muslim taxi drivers refusing service to passengers who were ferrying wine. The commission suspended the permits of drivers who refused to comply with service rules. It held that Muslim cab drivers didn’t have to transport booze, but if they chose not to, they couldn’t be an airport taxi driver. The appeals court agreed with the lower court that cab drivers who faced suspension didn't suffer irreparable harm. In 2013, a baker couple settled in Colorado (Oregon, USA) declined to make a wedding cake for a same-sex wedding. A state commission held they were violating the state’s non-discrimination statute while the bakers said the state was violating the free exercise of religion. They were fined $135,000, putting them out of business. In a similar case of 2012, baker Jack Phillips (Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Comm'n 06/04/2018) was disparagingly told by the commissioners at the Colorado Civil Rights Commission that religious beliefs cannot legitimately be carried into the public sphere or commercial domain.


The men who were installing the saffron flags in Nalanda requested locals to buy from these particular vends, an act very similar to what advertisers and salesmen do. In a similar incident, some Hindu fruit sellers of Jharkhand’s Jamshedpur have been booked by the police for writing ‘Hindu’ on their stalls. Additionally, legal action is being taken against shopkeepers under section 107 of CRPC. This section deals with action against persons who are likely to commit a breach of the peace or disturb the public tranquillity. It is blatantly unfair to deem the act of Hindus who wrote the word 'Hindu' on their fruit-shops as a breach of peace when we see many missionaries and Sai Kiranas, Ali tailors, Khalsa spare parts going about their businesses freely.


Similar to the American bakery cases, on 21st April, a man in Maharashtra's Thane district refused to accept delivery of items he had ordered online. The delivery agent complained to the police citing religious discrimination while the man claimed that the delivery agent was not wearing proper protective gear during the delivery despite the Coronavirus scare and he was wary of some videos and posts doing rounds on the internet where some showed the malevolent intention of spreading the Coronavirus by spitting, licking food items, attacking health-workers etc. It appears Maharashtra police feels it is illegal for a man to be scared of the Chinese Virus during a global pandemic caused by it. While there are laws against discrimination, they are no laws against misconstrued principles, this leads to societal friction hence breakage of fraternity. Bihar, Jharkhand and Maharashtra police are seeing a surge in saffron flags. Will they care to explain why?


Provocative comments or actions which have a destructive tendency to lead to an outburst of violence or disturbance of public order must be prevented. No democratic government can administer the nation unless there are public safety and public peace but the government must explain how and why it considers the installation of Hindu flags on Hindu shops and a legally tenable refusal of an individual for a business transaction. The delivery agent is a resident of Naya Nagar, Mira Road which falls in the Chinese virus Red Zone. The man not correct in turning him away if he found him not wearing masks and gloves. No reasonble man would take such risks.


Next, the police might allege that wearing a tika or a kalawa is a provocation. Was honourable Prime Minister’s call for ‘thaali bajao' a provocation too because people were lighting diyas and blowing shankhs? The governments can not escape such probing questions because if the governmental actions are wholly unjustified and draconian, democratic society has the right to judge them. Any legal action that assails life and personal liberty under Article 21 of the Indian Constitution must be tried by a court of law within the definitions of life and personal liberty as laid down by the honourable Supreme Court.


The deprivation of Article 21 of the Indian Constitution is only possible through the procedure established by law. In Meyer v. Nebraska (1923), hon'ble Supreme Court of the USA held that while the state has a legitimate interest in encouraging the growth of a homogenous population that can engage in discussions of civic matters, the does not mean that it can go overboard in this objective. pursue this objective is excessive. Without doubt, not merely freedom from bodily restraint but also the right of any individual to contract, to engage in any of the common occupations of life, to acquire useful knowledge to marry, establish a home and bring up children, to worship God according to the dictates of his conscience, and generally to enjoy those privileges long recognised at common law is essential to the orderly pursuit of happiness by free men1.


A man deserves full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of a place of public accommodation. If people belonging to only certain sections or groups are allowed to live freely by governments, the hallowed freedoms get hollowed out. Such a society is not governed by laws but by men of caprice organised within cabals and coteries. Such a society is trampled upon by governments by simply playing divide and rule, by pitting and favouring one group against the other, just like the colonial British did.


Harold Laski wrote - “The citizen seeks for happiness, and the state is an institution which exists to make his happiness possible. He judges this institution by its capacity to respond to the needs he infers from the experience he encounters. That experience is private to himself. Its predominant quality is its uniqueness. Either it is his own, or it is nothing. The substitution for it of someone else's experience is, where it is based upon constraint, a denial of freedom2.” We can see it around. More and more people are criticizing successive governments. People are gradually losing trust in governmental institutions as evidenced by rising protests, mob lynchings, militancy etc.


In recent times, social media platforms like WhatsApp, Instagram, Twitter and Tiktok have become means for sharing rumours, incitement, and misinformation. Fake news and rumours on WhatsApp have caused over 30 recorded deaths in 2019. Rumours such as the kidnapping of kids have led to the killing of individuals. How does police define rumour? Is every information not emanating from an official source or not permitted to be published by the censor a rumour? Rumours can be innocuous or provocative. Some provocative rumours that are fueling communal tensions are on the internet for all to see.


Democracy is a free market of thoughts and has a free trade in ideas, but selective and vested governmental actions are building walls of suppressed angst within the Indian democracy. How long before the angst turns to anger as we saw in the gruesome Hyderabad rape and encounter case? It is a universal truth that eternal vigilance is the price of liberty, another universal truth is that selective and biased vigilance means no vigil at all. It means corruption.


Justice Bhagwati wrote in Manubhai Tribhovandas Patel v. the State of Gujarat and Anr (12 Gujarat Law Reports 968), "It is not for the government of the day nor for the judges presiding over our court to decide what doctrine or philosophy is good for our people. It is for the people to choose what is best for them and in order that they may be able to make a wise and intelligent choice, free propagation of ideas is an essential requisite. The ideas propagated may be unorthodox and unconventional; they may disturb the complacency of a handful minority or they may challenge deep-seated, sacred, beliefs and question the most fundamental postulates of our social, political or economic thinking. There can indeed be no real freedom unless thought is free and unchecked, not free thought for those who agree with us but freedom for the thought that we hate. It is only from the clash of ideas that truth can emerge, for the best test of truth is the power of the thought to get itself accepted in the competition of the market.”


Learned Chief Justice Chandrachud spoke in Smt. Indira Nehru Gandhi v. Shri Raj Narain (AIR 1975 SC 2299) "That the nation shall be governed by a Government of laws, not of men is a pillar of our constitutional philosophy and therefore a pillar of the basic structure of our Constitution." The learned judge was re-iterating the firm basis for the Rule of Law theory, expounded by A. V. Dicey.


Eminent jurist and diplomat-politician par excellence MC Chagla once pondered over two questions. The first question is - Do we want to live in a Police State or in a democratic State? The second question is - “Do I want to live in a free society or a captive society? Do I as a follower of Mahatma Gandhi want to walk with my head up as a free man or am I going to be controlled, restricted and put down by an omnipotent Government? Absence of civil liberties makes a society a captive society3.”


The test of popular acceptance does not furnish a valid basis to disregard rights which are conferred with the sanctity of constitutional protection. Discrete and insular minorities face grave dangers of discrimination for the simple reason that their views, beliefs or way of life does not accord with the 'mainstream'. Does it deem the majority rights to be sacrificed at the altar of constitutional morality for no-fault? The word ‘Secular’ was not enshrined right from the beginning, it was implicit until its introduction into the Preamble of the Indian Constitution in 1976. Does it mean pre-1976 India can not be said to be secular? The learned Supreme Court eventually went on to list secularism under the basic structure doctrine.


Whether a particular feature forms part of the basic structure has to be necessarily determined on the basis of that provision of the Constitution. Subject to specific confinements, Article 25 presents a major ideal for everyone allowing one to not only to engage in such religious convictions as might be affirmed by conscience but also allowing to display convictions and thoughts by such unmistakable acts and practices which are authorized by faith4.


Presently, what rights are secured under the article is chosen by the courts. The courts have frequently gone into Hindu religious sacred texts to find out the status of a rite in question. It seems adherence to ‘secularism’ itself has become a religion which is problematic considering the Indian Constitution has no unequivocal meaning of “religion” or ‘matters of religion’. It is tough to believe that a millennia-old polytheistic civilisation was waiting for the validation of a modern government, a government that takes pride in secularism while twisting it in many 'innovative' ways5.


In Durgah Committee, Ajmer v. Syed Hussain Ali (AIR 1961 SC 1402), the learned Chief Justice Gajendragadkar observed, "Unless such practices found to constitute a fundamental piece of religion their case for the security under Article 26 may be precisely examined; as such, the insurance must be kept to such religious practices like a basic and a necessary piece of it and no other."


If one imagines a Hindu temple, the imagination has a high possibility of including a fluttering Hindu Patāka. Dr S Radhakrishnan spoke in the Constituent Assembly, "Bhagwa or the Saffron colour denotes renunciation of disinterestedness. Our leaders must be indifferent to material gains and dedicate themselves to their work6." The best way to lead is to lead by example. The police are supposed to lead the society by example, without fear and favour. As the wisdom goes, no man who has played an important role in society can ever hope or expect to be praised by all.


Mahatma Gandhi spoke on civil liberties - "Liberty of speech means that it is unassailed, even when the speech hurts; Evolution of democracy is not possible if we are not prepared to hear the other side. We shut the doors of reason when we refuse to listen to our opponents, or having listened, make fun of them. If intolerance becomes a habit, we run the risk of missing the truth7." On the rule of the majority, the Mahatma (Young India, 02-03-22) wrote, "The rule of the majority has a narrow application, i.e. one should yield to the majority in matters of detail. But it is slavery to be amenable to the majority, no matter what its decisions are. Democracy is not a state in which people act like sheep. Under democracy, individual liberty of opinion and action is jealously guarded."


The US Supreme Court held in the baker Jack Phillips' case that the government had no role in expressing or even suggesting whether the religious ground for Phillips’ conscience-based objection is legitimate or illegitimate since it was the bakery service that was being denied. The same-sex couple was treated as any other customer would have been treated, no better or no worse. Similarly, the fruit-sellers were not discriminating in trade. They are seeking more customers by the help of some friends who went around requesting people of their community to buy from the said fruit-sellers, which at last check, was completely legal. The man refusing a grocery delivery, upon seeing the delivery agent without a mask or gloves in the midst of a global Chinese virus pandemic, is well within his rights to protect himself and his kith and kin. He need not succumb to politeness at the cost of his life.


1 T Sareetha vs. T. Venkata Subbaiah (AIR 1983 AP 356) APHC
2 ‘Liberty in the Modern State’ (Chapter II, pages 94 & 95)
3 Chunibhai Vaidya vs. H.J. D'Penha 1992 GLH (1) 729
4 http://www.nja.nic.in/Concluded_Programmes/2018-19/P-1110_PPTs/6.Doctrine%20of%20Basic%20Structure.pdf
5 https://blog.ipleaders.in/right-freedom-religion-indian-constitution/
6 http://mha.nic.in/nationalflag2002.htm
7 https://www.thehindu.com/opinion/lead/What-it-means-to-be-independent/article14570147.ece

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