Environmental Law

Dr. Ram Manohar Lohiya National Law University

Project Topic – Noise pollution and right to make

noise in religious activities

Submitted to – Atul Kumar Tiwari (Faculty Member)

Submitted by –

Atul Pal

B.A.LL.B(Hons.) ‘VI sem’, Section - A

Roll No. – 38
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 TABLE OF CONTENT

 INTRODUCTION

 THE NOISE POLLUTION (REGULATION AND CONTROL) RULES, 2000

 JUDICIAL INTERPRETATIONS

 RESTRICTED USE OF LOUDSPEAKERS

 FREEDOM OF SPEECH AND EXPRESSION

 RIGHT TO MAKE NOISE FOR RELIGIOUS ACTIVITIES

 CONCLUSION

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INTRODUCTION

The word noise is derived from the Latin term "nausea". It has been defined as "unwanted sound,
a potential hazard to health and communication dumped into the environment with regard to the
adverse effect it may have on unwilling ears."1

Noise is defined as unwanted sound. Sound which pleases the listeners is music and that which
causes pain and annoyance is noise. At times, what is music for some can be noise for others.
Section 2 of the Air (Prevention and Control of Pollution) Act, 1981, includes noise in the
definition of air pollutant. It says

"air pollutant" means any solid, liquid or gaseous substance including noise present in the
atmosphere in such concentration as may be or tend to be injurious to human beings or other
living creatures or plants or property or environment”

Noise is more than just a nuisance. It constitutes a real and present danger to people's health. Day
and night, at home, at work, and at play, noise can produce serious physical and psychological
stress. None is immune to this stress. Though we seem to adjust to noise by ignoring it, the ear,
in fact, never closes and the body still responds-sometimes with extreme tension, as to a strange
sound in the night.2

One of the major sources of noise pollution is through religious gatherings, religious processions
and various other religious activities which take the use of loudspeakers and similar high decibel
devices in the process.

The Constitution of India declares that every person has a fundamental right not only to hold
whatever religious belief but also to express his beliefs in such overt acts, as are prescribed by
his religion and propagate its tenets among others.

1
http://en.wikipedia.org/wiki/Noise_pollution as visited on march12th, 2010.
2
Shyam Divan & Armin Rosencranz, Environment law and Policy in India (New Delhi, Oxford India Paperbacks,
2002)

3
The state is not supposed to interfere or giving any discriminatory treatment to the followers of
any religion. But when the question of propagating and practice is concerned, there are a few
exceptions to this freedom. The exercise of this right is, however subject to public order,
morality and public health. Here the Constitution succinctly expresses the limitations on
religious liberty that has been evolved by judicial pronouncements. The framers of the Indian
constitution attempted to establish a delicate balance between essential interference and impartial
interference on the part of the state. They kept in consideration the possibilities of arising out of
circumstances in which the government may have to impose restraints on the freedoms of
individuals in collective interests.

Pollution being wrongful contamination of environment which causes material injury to the right
of an individual, noise can well be regarded as a pollutant because it contaminates the
environment, causes nuisance and affects the health of a person and would, therefore, offend
Article 21, if it exceeds a reasonable limit. A number of different rulings have provided
guidelines for what is permissible, and what is not.

THE NOISE POLLUTION (REGULATION AND CONTROL) RULES, 2000

In order to curb the growing problem of noise pollution, the Government of India enacted the
Noise Pollution (Regulation and Control) Rules, 2000. Prior to the enactment of these rules noise
pollution was not being dealt specifically by a particular Act. There are provisions in Criminal
Procedure Code, 1973, Indian Penal Code, Torts etc but nowhere it has been dealt
comprehensively.

The rules are an addition to section 3 of the Environmental Protection Act of 1986. The EPA is
the umbrella legislation to deal with the every dynamic issue in relation to environmental
protection. The rules regulate noise levels in industrial, [75 decibels] commercial [65 decibels]
and residential zones [55 decibels], and also establish zones of silence (100 meters) near schools,
courts, hospitals, etc. The rules also assign regulatory authority for these standards to the local
district courts. Some important observations from the rules:

4
The rules are clearly a step forward although they do not attempt to create comprehensive
legislation on noise pollution, and continue with the piece-meal approach to specific problems
encountered over the years. They are further evidence that the legislative side has often lagged
judges' efforts to create and regulate a fine balance between competing demands - from religion,
the environment, public health, law and order, etc. As a result, notwithstanding progress in
understanding and documenting the various negative effects of noise pollution, there is still much
that remains undone.

The main provisions of the noise rules are as under:

1. The State Government may categorize the areas into industrial, commercial, residential or
silence areas/zones for the purpose of implementation of noise standards for different
areas.

2. The ambient air quality standards in respect of noise for different areas/zones has been
specified for in the Schedule annexed to the Rules.

3. The State Government shall take measures for abatement of noise including noise
emanating from vehicular movements and ensure that the existing noise levels do not
exceed the ambient air quality standards specified under these rules.

4. An area comprising not less than 100 meters around hospitals, educational institutions
and courts may be declared as silence area/zone for the purpose of these rules.

5. A loudspeaker or a public address system shall not be used except after obtaining written
permission from the authority and the same shall not be used at night i.e. between
10.00p.m. and 6.00 a.m.

6. A person found violating the provisions as to the maximum noise permissible in any
particular area shall be liable to be punished for it as per the provisions of these rules and
any other law in force.

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In case of Virendra Gaur v. State of Haryana3 after pointing out Article 48-A of the
Constitution about the Directive Principle which requires state to endeavor to protect and
improve environment and to safeguard the forest and wildlife of the country, Article 47 which
requires state to improve public health as its primary duty and Article 51-A (g) which imposes
fundamental duty on every citizen of India to protect and improve the natural environment
including forests, lakes, rivers and wildlife and to have compassion for living creatures, the
Supreme Court relied upon Article 21 to point out that enjoyment of life and its attainment
including their right to life with human dignity encompasses within its ambit, the protection and
preservation of environment, ecological balance free from pollution of air and water, sanitation
without which life cannot be enjoyed. It has been observed that it is imperative duty of state and
also Municipal Council to take adequate measures to promote, protect and improve both the
man-made and the natural environment.

As already seen there are not any comprehensive laws for curbing noise pollution in India. With
regards to Right to make noise for religious activities the law has been laid down through judicial
pronouncements. Nowhere has the right to religion and noise pollution have been expressly
defined. The provisions of the Constitution Articles 19, 21 and 25 have to be construed
harmoniously.

The Courts have looked into the Directive Principles of State while considering the
reasonableness of the restrictions They have balanced between the restriction imposed and the
social control envisaged; the prevailing social values as also social needs which are intended to
be satisfied by restrictions imposed have been borne in mind. The courts have always harped on
the point that there must be a direct and proximate nexus or a reasonable connection between the
restrictions imposed and the object sought to be achieved.

In has been held that use of mechanical instruments like loudspeakers and amplifiers is not
covered by the guarantee of freedom of speech and expression. The courts have also legitimized
seeking permission for using loud-speaker as not infringement of Article 19(1)(a) or Article 25

3
[ 1994 ] Supp 6 SCR 78
6
of the Constitution.4 The same logic has been used while deciding whether a person has right to
make noise under right to religion.

JUDICIAL INTERPRETATIONS

It is generally seen that n cases where there are huge religious celebrations, lots of loudspeakers,
sound mixers and loud musical instruments are used. This leads to a lot of inconvenience to the
general public not part of the celebrations. The courts have taken a strict view with regards to the
noise created by such acts. Public interest has always preceded religious interest.

RESTRICTED USE OF LOUDSPEAKERS

The activism regarding the noise pollution can be traced way back to 1952 where the Bombay
High Court in the case of State of Bombay v Narasu Appa Mali5 asked authorities to regulate the
use of loudspeakers during night when the Ganesh and Navratri festivals were being celebrated.
The Court ordered the strict implementation of Environmental Acts, ruling that the means of
celebration of festivals must not disturb the peace and tranquility of the neighborhood.

In Rajni Kant Verma v. State6, it has been held that use of mechanical instruments like
loudspeakers and amplifiers is not covered by the guarantee of freedom of speech and
expression. The learned Judge further held that a bye-law of a municipality which requires
permission of the Executive Officer for using a loud-speaker does not infringe Article 19 (1)(a)
of the Constitution.

FREEDOM OF SPEECH AND EXPRESSION

In P.A. Jacob v. the Superintendent of Police,7 it was said that the right to speech implies, the
right to silence. It implies freedom, not to listen, and not to be forced to listen. The right
comprehends freedom to be free from what one desires to be free from. Free speech is not to be
treated as a promise to everyone with opinions and beliefs, to gather at any place and at any time
and express their views in any manner. The right is subordinate to peace and order. A person can
4
Rajni Kant Verma v. State, MANU/UP/0084/1958
5
AIR 1952 Bom 82
6
AIR 1958 All. 360.
7
MANU/KE/0001/1993
7
decline to read a publication, or switch off a radio or a television set. But, he cannot prevent the
sound from a loudspeaker reaching him. He could be forced to hear what, he wishes not, to hear.
That will be an invasion of his right to be let alone, to hear what he wants to hear, or not to hear,
what he does not wish to hear. One may put his mind or hearing to his own uses, but not that of
another. None has a right to trespass on the mind or ear of another and commit auricular or visual
aggression. A loudspeaker is mechanical device, and it has no mind or thought process in it.
Recognition of the right of speech or expression is recognition accorded to a human faculty.

A right belongs to human personality, and not to a mechanical device. One may put his faculties
to reasonable uses. But, he cannot put his machines to any use he likes. He cannot use his
machines to injure others. Intervention with a machine is not intervention with, or invasion of a
human faculty or right. No mechanical device can be upgraded to a human faculty. A computer
or a robot cannot be conceded the right under Article 19 (though they may be useful to man to
express his faculties). No more, a loudspeaker. The use of a loudspeaker may be incidental to the
exercise of the right. But, its use is not a matter of right, or part of the right".

Thus the Supreme Court ruling helped make a clear position on freedom of expression. Freedom
or right, is not an exclusive matter between the State and a citizen. One man's freedom, may
destroy another man's freedom. A community of rights, not always synchronizing with each
other, has to be harmonised, if any freedom is to be real.

RIGHT TO MAKE NOISE FOR RELIGIOUS ACTIVITIES

The Supreme Court in the case of Church of God (Full Gospel) in India v. :K.K.R. Majestic
Colony Welfare Association8 ( Appeal) had to decide whether a particular community or sect of
that community can claim right to add to noise pollution on the ground of religion.

The court said that the religious teachers or the spiritual leaders who had laid down these tenets,
had not in any way desired the use of microphones as a means of performance of religion. While
deciding whether there was any right to religion breached by such a limitation the court said that
the provision of Article 25 is subject to the provisions of Article 19(1)(a) of the Constitution. On

8
AIR 2000 SC 2773
8
true and proper construction of the provision of Article 25(1), read with Article 19(1)(a) of the
Constitution, it cannot be said that a citizen should be coerced to hear anything which he does
not like or which he does not require.

In any case, if there is such practice, it should not adversely affect the rights of others including-
that of being not disturbed in their activities. The court referred to the Constitutional Bench
judgement of Acharya Maharajshri Narendra Prasadji Anand Prasadji Maharaj and Ors. v.
The State of Gujarat and Ors9. Where in the court had observed that

"no rights in an organized society can be absolute. Enjoyment of one's rights must be consistent
with the enjoyment of rights also by others. Where in a free play of social forces it is not possible
to bring about a voluntary harmony, the State has to step in to set right the imbalance between
competing interests".

The Court also observed that a particular fundamental right cannot exist in isolation in a water-
tight compartment. One fundamental right of a person may have to co-exist in harmony with the
exercise of another fundamental right by others also with reasonable and valid exercise of power
by the State in the light of the directive principles in the interests of social welfare as a whole.

While drawing a harmony between both the provisions the court reasoned that no religion
prescribes that prayers should be performed by disturbing the peace of others nor does it
preach that they should be through voice amplifiers or beating of drums. In our view, in a
civilized society in the name of religion, activities which disturb old or infirm persons, students
or children having their sleep in the early hours or during daytime or other persons carrying on
other activities cannot be permitted. It should not be forgotten that young babies in the
neighborhood are also entitled to enjoy their natural right of sleeping in a peaceful atmosphere. A
student preparing for his examination is entitled to concentrate on his studies without their being
any unnecessary disturbance by the neighbors. Similarly, the old and the infirm are entitled to
enjoy reasonable quietness during their leisure hours without there being any nuisance of noise
pollution. Aged, sick, people afflicted with psychic disturbances as well as children up to 6 years
of age are considered to be very sensible (sic sensitive) to noise. Their rights are also required to
be honored.
9
1975 (1) SCC 2.
9
In the case of Church of God (Full Gospel) In India rep. by its State Council Chairman, P.
Wellesly Solomon v. K.K.R. Majestic Colony Welfare Association (Madras) the court said that
people should practice their respective faith in a cultured way and not to resort to aggressive or
unfair methods and resorting to a method of worship which is inhuman. God, to whichever
religion he belongs to, is said to be present everywhere and does not require a blaring and
deafening amplifier to hear the prayer of his devotees. The nature of evil and adverse effects
which noise pollution causes to the children, aged, sickly, pregnant women and even normal
individuals and how it disturbs the student community etc., have been repeatedly emphasized
with scientific facts and figures, any number of times in newspapers, magazines, health journals
and other media.

Moreover, where there is a clash of two Fundamental Rights, as in the instant case, namely, the
right to profess as part of right to religion and right to lead a healthy life which is her
Fundamental Right under Article 21, the right which would advance the public morality or
public interest, would alone be enforced through the process of court, for the reason that moral
considerations cannot be kept at bay.10

In Forum, Prevention of Environment & Sound Pollution v. Union of India and Anrs11 the
court discussed The Noise Pollution (Regulation and Control) Rules, 2000 which imposed
restrictions on the use of loud speakers/ public address system. Exception of this rule is that the
state government can permit use of loudspeakers on public address system during any festive or
religious occasion for certain time (10:00 P.M. to 12:00 midnight) with certain limitations.

This sub rule (3) had been inserted through Amendment Rules 2002 w.e.f. 11 th Oct, 2002 and
therefore, its constitutional validity had been challenged in the High Court of Kerela. The High
court had dismissed the petition holding that sub rule was intra vires. The aggrieved petitioners
has filed special leave petition in Supreme Court. The Supreme Court stated that use of loud
speakers cannot be must for performing religious acts and no religion ever says to force the
unwilling to listen the expressions of religious beliefs. The court opined that the passage quoted

10
Mr. Mahesh Bhatt and Kasturi and Sons v. Union of India (UOI) and Anr. 2008 BusLR 366 (Del)
11
AIR2006SC348
10
in the newspaper stated the factual position as to the objective of several religions and their
underlying logic.

However, keeping in view the diversity of cultures and religions in India, the Court justified the
limited power of exemption from operation of the Noise Rules granted by the Central
Government as its statutory power. The power to grant exemption is conferred on State
Government but the State Government exercise the power with due care and caution and in
public interest.

 As per court opinion the state government should specify in advance, the number and particulars
of the days on which such exemption will be operative, and it should not apply to silence zone
areas. The Court therefore, clarified the position of law. The court asserted that, it only upheld
the constitutional validity of the Noise Pollution Rules framed by the Central Government in
exercise of its statutory powers. Accordingly, the appeal was dismissed and the judgment of the
High Court was affirmed with certain clarifications.

In Vinayaga Chathurthi Madhya Kuzhi v. State of Tamil Nadu12, a right to take Vinayaga idol
in procession along a particular route was claimed. The Bench held that it was not an absolute
right but subject to regulation and imposition of restrictions. The Bench pointed out that the
rights guaranteed under Articles 19(1)(b), 25 and 26 of the Constitution of India could not be
claimed as absolute rights and observed that any right claimed as absolute right would not be
exercisable as there would be no orderliness in exercising such a right and as a result thereof it
would affect the rights of the other persons who also enjoyed similar rights that Articles 25 and
26 opened with the words ‘subject to public order, morality and health’ that temporary orders for
prohibition of meeting or procession to prevent imminent breach of peace were reasonable
restrictions.

In Shaikhismail Sahib v. Nirchinda Venkatanrasimhulu Iyah13, the plaintiff brought an action

for injunction against the defendant for having let his house to people to perform Pujas on which
occasions loud music and noise in connection with the ceremonies caused such disturbance as to
amount to an actionable nuisance and it was actually found that the noise was such that it

12
1997 MLJ (Crl) 142.
13
AIR 1936 Mad 905.
11
prevented the people in the neighborhood from having proper sleep during nights. It was held
that since there could be no doubt that the noise in the case was not produced by ordinary music
but by loud and discordant instruments like the tom-tom, cymbals, and so on, and when such
noise was made long after the hour when people would ordinarily retire for the night, it should
necessarily amount to an actionable nuisance.

In the case of Chairman, Guruvayur Devaswom Managing Committee, Guruvayur v.

Superintendent of Police, Thrissur14, the Kerala High Court allowed the Guruvayur temple to
use loudspeakers. This was allowed as the court felt that it was integral to the ceremony as
thousands of devotees thronged the temple for the ceremony. Thus it should be noted in this
regard that permission was given only when the court felt that without the same the faith of the
devotees will be hampered. But the court even added a reminder that the temple should make
sure that the noise is to its lowest possible level.

In the case of Maulana Mufti Syed Barkati v. State of West Bengal15, it was held that calling of
Azan through loudspeakers is not an integral part of the religion of Islam. Use of Islam was a
technological development and not a part of Islam.

In the landmark judgment of In Re: Noise Pollution - Implementation of the Laws for
restricting use of loudspeakers and high volume producing sound systems 16
the matters before the Court raised certain issues of far- reaching implications in day-to-day life
of the people in India relatable to noise pollution vis-à-vis right to life enshrined in Article 21 of
the Constitution of India as interpreted in its wide sweep by the constitutional courts of the
country. Though a limited grievance was raised to begin with but several interveners and
interlocutory applications enhanced the scope of hearing and the cases were heard in a very wide
perspective centering around Article 21 of the Constitution. Several associated and incidental
issues have also been gone into.

The Court in this case discussed in detail several questions, such as what is noise? What are its
adverse effects? Whether noise pollution runs in conflict with the fundamental rights of the
people? And what relief can be allowed by way of directions issued in public interest?
14
AIR 1998 Ker 122.
15
AIR 1999 Cal 15.
16
AIR 2005 SC 3136.
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After examination of these questions the Court came to the following conclusion with regards to
usage of loudspeakers: The noise level at the boundary of the public place, where loudspeaker or
public address system or any other noise source is being used shall not exceed 10 decibel above
the ambient noise standards for the area or 75 decibel whichever is lower. No one shall beat a
drum or tom-tom or blow a trumpet or beat or sound any instrument or use any sound amplifier
at night (between 10. 00 p.m. and 6.a.m.) except in public emergencies. The peripheral noise
level of privately owned sound system shall not exceed by more than 5 decibel than the ambient
air quality standard specified for the area in which it is used, at the boundary of the private place.
The States shall make provision for seizure and confiscation of loudspeakers, amplifiers and such
other equipments as are found to be creating noise beyond the permissible limits. Rule 3 of the
Noise Pollution (Regulation and Control) Rules, 2000 makes provision for specifying ambient
air quality standards in respect of noise for different areas/zones, categorization of the areas for
the purpose of implementation of noise standards, authorizing the authorities for enforcement
and achievement of laid down standards. The Central Government/State Governments shall take
steps for laying down such standards and notifying the authorities where it has not already been
done.

CONCLUSION

The right to life includes the right to live with human dignity and all that goes along with it,
namely, the bare necessities of life such as adequate nutrition, clothing and shelter and facilities
for reading, writing and expressing oneself in diverse forms, freely moving about and mixing and
commingling with fellow human beings. Every act which offends against or impairs human
dignity would constitute deprivation pro tanto of this right to live.

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In the upshot of aforesaid discourse, it may be submitted that the Supreme Court of India, being
the final interpreter of the provisions of the Constitution of India, has done its job in a
tremendous way. Law is an instrument of social control. In case of any conflict between
competing interests, one may recourse to Social Engineering implying the striking the balance by
measuring the importance of various interests.

Though there is no yardstick to determine the importance of interests but the agencies concerned
with law can bring the harmony by applying the 'Harmonious Rule of Construction'. Harmonious
rule provides that in case of conflict between the two provisions of the same statute or where two
provisions cannot stand together, the courts should try to give effect to both the provisions in
harmonizing way. The basic presumption behind the rule or harmonious construction is that the
legislature must never have intended to contradict itself. This conflict can be resolved by making
one provision a general rule and the other as an exception. In consonance with the same
approach, the Supreme Court has so far attempted to give effect to both the provisions.

When the quandary has not been resolved, it was expounded though Freedom of Religions is one
of the fundamental rights and the word 'secular' signifies non interference in the affairs of the
individual and God, but it is not absolute as the language of Article 25 (1) clearly states 'Subject
to public order, morality and health ' and Article 25(2) empowers the state to make laws
regulating or restricting any economic, financial and particle or other secular activity which may
be associated with religious practice. The state has the power to make laws for providing for
social welfare and social reforms even if these laws amount to interference with religious.17

Therefore no person can claim a right to make noise in furtherance to his right of religion if it is
causing inconvenience to the public as this will lead to chaos and thus he has to be subject to the
limitations and conditions imposed by the state.

The Supreme Court has also become strict with respect to implementation of the same. In the
case of Yashwant Trimbak v. State of Maharashtra18said that enactment of a law, but tolerating
its infringement is worse than not enacting law at all. The continued infringement of law, over a
period of time, is made possible by adoption of such means which are best known to the violators

17
Om Birangana Religious Society v. The State' and Ors. MANU/WB/0254/1996
18
MANU/MH/0453/1995
14
of law. Thus the court wanted the state to take requisite action. Implementation of law holds key
to the effectiveness of law.

There are instances were in the court have relaxed the law but only when there has been absolute
necessity and no other alternative has been available. But with such concessions the courts have
even imposed reasonable conditions which have to be compulsorily complied with.

It cannot be said that the religious teachers or the spiritual leaders who had laid down these
tenets, had any way desired the use of microphones as a means of performance of religion.
Undoubtedly, one can practice, profess and propagate religion, as guaranteed under Article 25(1)
of the Constitution but that is not an absolute right. The provision of Article 25 is subject to the
provisions of Article 19(1)(a) of the Constitution. On true and proper construction of the
provision of Article 25(1), read with Article 19(1)(a) of the Constitution, it cannot be said that a
citizen should be coerced to hear any thing which he docs not like or which he docs not require.
Therefore right to make noise is not absolute and has to follow the guidelines and rules laid
down by the courts and the appropriate authorities.

BIBLIOGRAPHY

Books
1. Shyam Divan & Armin Rosencranz, Environment law and Policy in India (New Delhi,
Oxford India Paperbacks, 2002)
2. Stuart Bell & Donald Mc Gillivray, Environmental Law (Delhi, Universal Law
Publishing Co. Pvt. Ltd., 5th Edn., 2000)

Web links:

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 1. http://en.wikipedia.org/wiki/Noise_pollution
2. http://www.legalserviceindia.com/articles/noip.htm

Cases
1. Virendra Gaur v. State of Haryana [ 1994 ] Supp 6 SCR 78
2. Rajni Kant Verma v. State MANU/UP/0084/1958
3. State of Bombay v Narasu Appa Mali, AIR 1952 Bom 82
4. Rajni Kant Verma v. State, AIR 1958 All. 360
5. P.A. Jacob v. the Superintendent of Police, AIR 2000 SC 2773
6. Church of God (Full Gospel) in India v. :K.K.R. Majestic Colony Welfare Association
( Appeal), AIR 2000 SC 2773
7. Acharya Maharajshri Narendra Prasadji Anand Prasadji Maharaj and Ors. v. The State
of Gujarat and Ors ,1975 (1) SCC 2.
8. Church of God (Full Gospel) In India rep. by its State Council Chairman, P. Wellesly
Solomon v. K.K.R. Majestic Colony Welfare Association (Madras)
9. Forum, Prevention of Environment & Sound Pollution v. Union of India and Anrs
10. Mr. Mahesh Bhatt and Kasturi and Sons v. Union of India (UOI) and Anr. 2008 BusLR
366 (Del)
11. Vinayaga Chathurthi Madhya Kuzhi v. State of Tamil Nadu, 1997 MLJ (Crl) 142.
12. Shaikhismail Sahib v. Nirchinda Venkatanrasimhulu Iyah, AIR 1936 Mad 905
13. Chairman, Guruvayur Devaswom Managing Committee, Guruvayur v. Superintendent
of Police, Thrissur Maulana Mufti Syed Barkati v. State of West Bengal, AIR 1999 Cal
15.
14. In Re: Noise Pollution - Implementation of the Laws for restricting use of loudspeakers
and high volume producing sound systems, AIR 2005 SC 3136.
15. Yashwant Trimbak v. State of Maharashtra MANU/MH/0453/1995
16. Om Birangana Religious Society v. The State' and Ors. MANU/WB/0254/1996

16