Chhattisgarh High Court Rejects Plea Against Recital Of Saraswati Vandana, Gayatri Mantra In Schools; Says They're 'Moral Instruction'
The Chhattisgarh High Court has upheld State's order on recital of the National Anthem, National Song, Deep Mantra, Saraswati Vandana, Guru Mantra, Shanti Mantra and accounts of the lives of Great Personalities (Mahapurushas) in schools at the beginning day along with Rajya Geet (State Song), Gayatri Mantra and Shanti (Peace) Mantra at the end. [2026 LiveLaw (Chh) 57]
The court dismissed as "premature", the plea challenging State's June 12 order, observing that the order did not mandate any coercive direction compelling students to act against their religious beliefs nor was any material placed by petitioners to show violation of freedom of religion.
It further held that the order did not violate Article 28(1) of the Constitution of India as the provision does not ban any moral instruction disassociated from any denominational doctrines.
Justice Amitendra Kishore Prasad referred to the State Government's order and said:
"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 contents of the impugned order, read as a whole, do not disclose any express requirement obligating students to participate in any activity that would interfere with their constitutionally protected freedom of religion or freedom of conscience. Furthermore, the petitioners have completely failed to place any relevant material on record to show violation of any fundamental rights as no individual or direct injury has been shown".
The court also observed that the the expression “religious instruction” used in Article 28(1) (as per which no religious instruction shall be provided in any educational institution wholly maintained out of State funds) "has a restricted meaning".
The court said that signifies that the "teaching of religious customs, rituals, practices and modes of worship" is strictly prohibited in educational institutions wholly maintained out of State funds.
"However, a plain reading of clause (1) of Article 28 makes it clear that the provision 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. In light of the foregoing, this Court is of the opinion that the petition is entirely premature, based on mere apprehension rather than any actual grievance. Thus, at this stage, the reliefs sought by the petitioners cannot be granted".
The petitioners argued that the order is violative of Articles 14, 21, 25, 28(1), 29 & 30 of the Constitution of India creating an impermissible situation wherein students from minority communities may feel compelled to participate in and recite religious practices that do not belong to their faith. It was contended that the impugned direction is contrary to the constitutional mandate of secularism, which guarantees that India is a nation wherein no individual can be directed to follow or practice any specific religious faith.
The petitioners asserted that the chanting of Saraswati Vandana, Gayatri Mantra, Guru Mantra and Shanti Mantra amounts to imparting religious instructions and promoting a particular religion in Government Schools, which is constitutionally barred.
Meanwhile the State argued that the challenge is based on speculative apprehensions rather than any concrete injury. The impugned policy involves neither religious instruction nor conversion and is in perfect alignment with the National Education Policy, 2020 (NEP 2020), which mandates the integration of the Indian Knowledge Systems (IKS) to foster cultural awareness.
He was submitted that the morning routine is designed solely to foster unity and focus among students. The order prescribes no negative consequences, punishment or disciplinary action against any student who chooses not to recite these verses. It was also argued that the traditional versus like the Shanti Mantras and Bhojan Mantras are ancient Indian philosophies that promote universal well-being, ecological balance and gratitude.
The court dismissed the plea as premature, granting liberty to the petitioners to approach the court afresh if any exigency arises in the future.
Case title: Abdul Salam Rizvi & Ors. v/s State Of Chhattisgarh & Ors.
WPC No. 3372 of 2026
Citation: 2026 LiveLaw (Chh) 57