Jaising: doctrine of proportionality has never been invoked when there is a clash but as administrative principle when the state action is arbitrary. this court has given the test of harmonisation in devaru and essential practice.

in devaru, substantial injury aspect is also there to see which gets eclipse. I suggest with stick to harmonisation. there was one principle where a HIV person didn't disclose it to his wife- the court used doctrine of harmonisation along with essential religious practice test and substantial injury.

on untouchability- it didn't exist in the english language in the 19th century.