Case Comment: Subhash Bhattacharjee v. State of Tripura (Balancing Customs, Religious Freedom & Animal Rights)

I. Introduction

“When Customary practices such as animal sacrifice, conflict with constitutional mandates, the law must prioritize rights and welfare over tradition, ensuring that customs do not override the dignity and the protection afforded to all beings.”- Upendra Baxi.²

Tripura, the 3^rd smallest State of the nation, Upholding a rich cultural heritage with the history of 186^th kings of the Manikya Dynasty ³. There are 19 indigenous groups residing over the state in friendly state with the neibouring Bengali population. It is reach in its culture & tradition starting from ancient Wathopism⁴ to Shamanistic rituals inspiring from its Tibeto-Mongoloid ⁵origin mixed with Indian tradition and forming a Tripuri⁶ Version of Practices.

The kings of Tripura since time immemorial, had felt the need for making this indigenous groups united with the main populations of the cities of the state. The need was later fulfilled when the kings started forming a mutual covenant with the population. Each tribe got its own covenant base on its Unique characteristics. It first come across oral tradition and later got developed into manuscripts that Tiprasa ⁷people Commonly called as “Hoda Ni Dharma Raida”⁸ which can be slightly translated as Customary Laws of the Community.

This Customs includes the laws governing Birth, Marriage & Death. The Tiprasas, the indigenous inhabitants of the state believes in nature worship and in Shamanistic rituals in the past as Descending from its East Asian Origin. The Then Kingdom of Tipperra ⁹is so ancient that the Rajmala¹⁰ , Mentions its existence during the Period of Mahabharata and Puranic times of India as Analysed it R.H.SHyed Hutchinson¹¹During his expedition to Cittagong ¹²Hills. As Time passes, Tripura inherit the title of Pitha Sthan of shakti, ¹³One of the Shakti Peeth as per Devi Bhagwatam ¹⁴and Kalika Puran ¹⁵where the right foot of the Goddess Sati fells as per mythology and records turning Tripura in a major Pilgrimage site for Trantric practitions and those with Hindu Faith. The King also holds its traditional deities Sri Chaturdasha Devtas or Kwthar Chibrwi Mwtai, the Sacred 14 Dieties, the worship of the gold-siver heads of the mwtais which is purely manage by a set of royal priests known as Deorais and its head Chontai in lead¹⁶. This Sacred sites in the state were served with strict rules follows as per royal custom and indigenous faith with Dharmic rules where both Brahmins and Ochais will took part in ceremony. As mentioned earlier, the Tiprasas of Tripura the traditional inhabitants are the followers of nature and shamanistic rituals. Thus, Sacrifices in the name of deities were common for daily livelihood. It is one the most common traits among Clans and tribal groups. Not a new thing in Tantra¹⁷ that the concept of Bali daan ¹⁸exist way back to 12^th C.E in the records of Kalika puran and Yogini Tantra¹⁹. Hence Animal Sacrifices came into being practiced in Tripura. The most uncommon trait of Hinduism but once considered to be essential element of Dharma.

For centuries, Animal sacrifices has been a Contentious practice in various cultures and beliefs in India. This issue has sparked intense debates since Initial Stages of Bhakti Movement by saints and sages till today’s Gen Z Era, with proponents arguing that it’s an essential part of their religious tradition, while opponents contend that it’s cruel and outdated practice.

As the Kingdom Undergone significant transformation since its merger agreement, which marked Tripura’s Integration into the Indian Union, Laid the groundwork for its evolving identity within a larger national framework in 1972 and 23^rd march of 2013, Tripura got its own High Court replacing the court of Judicial Commissioner.

Henceforth, High Court of Tripura started functioning actively ensuring Natural Justice to all including Animals. In this landmark Judgment, The Tripura High Court addressed a critical and most controversial issue at the cross paths of faith, Culture, and Animal welfare.

The Case of Subhash Bhattacharjee V. The State of Tripura(2019) revolves around the constitutionality of animal sacrifice in the temples, specifically the famous Tripureshwari Devi Temple (matabari) and Chatur Das Devta Temple in the state.

II. Background & facts

The Public Interest Litigation, Writ Petition was Filed by a retired judge Subhash Bhattacharjee before the High Court of Tripura challenging the practice of animal sacrifice at the Tripureshwari temple, a revered shakti peetha & to ChaturDas Devta Temple ( The Traditional Royal Dieties ) . It was pleaded by the petitioner that everyday under the guidance of the District administration, The Government of Tripura provides one he goat to the temple of Tripureshwari and in certain occasions, a number of sacrifices were also performed by the devotees. It is orally argued at the same that the Chatur Das Devta Temple also followed the same pattern of ritual sacrifices. The petitioner argued against the ritualistic sacrifice performed before the deities. The petitioner citing articles of the constitution of India tried to make effort on analyzing the validity of this religious practices being followed in these temples of Tripura, It is contended that the practice is against the constitutional mandate and the spirit as such practices induces psychological effect to the viewers. The place is also one of the important tourist attraction and the pilgrimage site which attracts thousands of devotees where this barbaric performance of animal sacrifice that took place in Nat Mandir which makes the whole nature around the premise with superstitious sensitivity in the minds of the devotees. The petition also highlights the events which lead to the construction of the temple by King Dhanya Manikya in 15^th C.E. The petition also highlights in para 4 of the judgement that the Animal sacrifice is continued in various parts of India and Nepal citing the case of Gudhima Temple were the judicial order has been passed on the ban of animal sacrifice and same is followed in the temples of Himachal Pradesh where it has been prohibited.

The state as in Defense filing an affidavit in reply has stated that the petition filed deserved to be dismissed owing to the fact that the petitioner did not approach to the Government of Tripura and without issuing any notice to the temple authorities filing an instant writ petition under Article 226 of the constitution of India, contended that the animal sacrifice is an essential and important part of the worship of the presiding deities. The defense asserted that the practice of offering sacrifices- such as goats, pigeons, Sheep and buffaloes at the temple is a long practiced culture. The Government in response also submitted various documents in references to demonstrate that the practice has been part of the temple’s rituals for centuries.

The High court led by Chief Justice Karol, examined whether the practices are protected under Article 25 of the Constitution of India, which guarantees religious freedom. The Bench also cites concerns about animal cruelty and public health and try to interpret the major portion of the constitutionality of the Custom being practiced. The Defense contended that the petition filed is not is conscience with the judicial process.

It is highlighted that the terms and conditions prescribed in the Merger Agreement with the Dominion of India that the State would worship the Mata Tripureshwari temple and the Chatur Das Temple along with other royal temples in a traditional system as those [practices were followed way before independence from the reign of the kings of Tripura and animal sacrifice is an essential practice followed time immemorial by the Tripuris.

It is also highlighted by the state that the Sacrificial practices in the these temples are align with the Tantric Cult as the Tripureshwari temple is one of the 51 Shakti peetha as per scriptures and thus follows the Shakta tradition of worship.

The Defense argued that the petition is filed targeting to the Hindu religion as no points were being raised on Bakri-Eid celebrated by the Muslims presuming the petition as Anti- Hindu.

It is further acknowledge by the scholars that in India, there are certain practices such as animal sacrifice which are followed as custom to their belief way before the developed concept of God or Allah.

The learned Advocate General on behalf of this placed three records as

• A Statistical Account of Bengal relating to Chittagong Hill Tracts 1876.
• Imperial Gazetteer of India
• Minutes of the meeting 18^th June 1982 in connection with the managements of temples in Tripura.

III. Issues

• Whether animal sacrifice is an essential And Integral part Of Hinduism?
• Whether the practice of animal sacrifice infringes upon the fundamental rights of animals under Article 21 of the Indian Constitution?
• Whether the state can restrict or regulate such customary practices under Article 25(2)(a) of the Constitution?
• Whether the prevention of Cruelty to Animals Act, 1960 applies to animal Sacrifice in temples?
• Whether the state has a duty to protect animal and look for its welfare and prevent cruelty?

IV. Rules

Upon the issues, it was well discussed by the Court in relation to application of “essential religious practice” test to determine whether the practice of the animal or blood sacrifice is an essential practice of these temples or not. The rule says only those practices are integral part to a religion that can be protected under article 25 of the constitution of India. It was well interpreted by the bench the concept of Article 25 of the Constitution that it guarantees the freedom of freely professes, Practice and propagate religion. At the same, It is also laid in the rule that Article 25 is subjected to public order, morality, health, and other fundamental rights guaranteed under part III of the constitution. It intends toward the principle that the right to religious freedom is not absolute and can be restricted when it conflicts with other rights, such as the right to life and dignity, which extends to animals. It is understood that such rights are not absolute and unfettered and is reasonably restricted based on public order, Morality and health, and other provisions of the Part III of the Constitution.

The Judgment required a thorough interpretation of the Part III²⁰, Part IV ²¹and Part IVA²² of the constitution of India

PART III-

• Article 21 Protection of life and Personal liberty.
• Article 25 Freedom of Conscience and Free Profession, Practice and propagation of religion-
• Article 26 Freedom to manage religious affairs

Part IV

Article 48 talks about the Organization of agriculture and animal husbandry as it emphasize towards the duty of the state to cater and preserve the breed, prohibiting the slaughter of cows and other milch and drought cattle.

Article 48 A emphasize the state toward protecting and preserving wildlife and forest environment. The Term Wildlife even though it is not been defined in this, but would include the Word “any living being” which is important to form a chain of living organism.

Part IV-A

Art.51 A mentions that it is the duty of the citizens of India to protect, develop and safeguard natural environment which include the Forest, rivers and wildlife with Compassion towards living creatures.

Prevention of cruelty to Animals Act 1960 – Chapter IV Sec 28 says that nothing in the Act shall render any offense in relation to killing of animal in a manner required by the religion of any community. It Aims to prevent infliction of unnecessary pain or suffering on animals.

Wildlife Protection Act 1972 provides for the protection of wild animals, birds, and plants with a view to ensuring ecological and environmental security.

V. Analysis of judgement

The Court recognized Article 21 that the right extends to animals as well as the interpretation of “life” includes the right to live without suffering unnecessary pain. It emphasizes on the need to prevent pain that incurred during traditional practices such as Jallikattu. ²³

The Supreme Court also upheld that the word “person” includes animals in specific contexts as stressing to the point of treating animals with dignity and ensuring they are not subjected to cruelty.²⁴ Thus, the life of animal cannot be deprived as it is save and given exception in accordance with the procedure established by law which means due process of law.²⁵

Article 25 showed some lights towards practices and it can be interpreted as it has to be integral and essential part of practice of any religion.

The religion may not only lay down a code of ethical conducts but it might prescribe rituals and observances, ceremonies and modes of worship which are regarded as integral parts of religion. ²⁶What Article 25 (2)(a) contemplates about is not just related to the state regulation to religious practices except when the right opposite to public order and morality but also the activities which involves economic, commercial and the political characteristics in relation to religious activity.²⁷

The right guaranteed under article 25 is an individual right and hence all the members of the community can practice the right. A person has the right to use his free will while practicing any sort of belief as according to his conscience. It will be unfettered as long as it does not go against public order, etc.²⁸

The Decisions in the landmark cases such as Mahant Jagannath Ramanuj Das v. Sate of Orissa 1954, Sri Venkataramana Devaru V. State of Mysore 1958, Durgah VCommittee, Ajner v, Syed Hussain Ali 1961 as opined by judges firmly established the principles underlying these articles. The Article 25 and 26 id not confined merely on the doctrines or beliefs but also extend to acts performed in the exercise of the religion. This protection includes rituals, ceremonies, modes of worship etc.

The court interpret to the concept of essential practices brought the need of co- existence and tolerance, the very spirit spirit of the ancient thought in the scriptures of taking care is to look upon all the living beings as one as friends, for in all of them resides one soul.²⁹This is held in the judgment of A.S Narayana Deekshitulu v. State of A.P (1996). The judgment later brought reforms over the practice bringing down the old social orders and the with a change in societal perspective through introducing certain changes both in religion and institutions developed through religion such as the practice of Archaka where it has said that the performance of a religious Act is an integral part of religion but the hereditary priest is not.

In Sabirimala Case it has been said that there cannot be a point of event or date particular which declare that the so and so forth practices came into existence due to it that incident and can be considered integral part of religion as such practices arising out of it can be altered any time with the conscience of Human being and thus cannot be considered as “Core”.³⁰

In the issue of Constitutional morality for the purpose of article 25 and 26 Justice D. Y Chandrachud opined that the right to freedom is not a stand alone right as it is an important and most essential part to the entire chapter of fundamental rights and constitutional articles which recognizes rights and liberty as in Part III.

Hon’ble Justice Ms. Indu Malhotra made an observation that “reference is required to be made to the doctrines and tenets of a religion, its historical background and scriptures to ascertain the essentiality of religious practices.”

The Court make a thorough analysis on Constitutional Morality³¹, Public Order and health by citing various landmark cases.

While interpreting the concept of Hinduism , The court observed that the Hindu Religion itself comprises of various sects and each sect has its own tradition with a deity . There is no concept of One God Manifestation but many and thus there is a number of sets of Gods and Goddesses that has came into existence as we see the series of development Over centuries. It means that by time to time, there were various events that records a sage or a saint trying to interpret the Hindu Philosophy and attempted to remove from the Hindu thoughts and viewpoints the idea of corruption and superstition that led to the formation of various sect that we saw today. ³²The Court also pointed out certain acts which cannot be considered as integral part while applying the Essential Practice Test through Landmark Cases as such-

• The Slaughtering of Animals.³³
• The Hereditary possession of priesthood.³⁴
• Practices contrary to constitutional ethos and violates rights of others.³⁵
• Practices that violates freedom of practice and profess one’s religion.³⁶

The court highlights the statutory framework governing animal slaughter, specifically pointing to the Prevention of Cruelty to Animals (Slaughter House) Rules, 2001. It mandates that slaughterhouses be properly constructed and maintained with strict health protocols, including the isolation of slaughtered animals and ensuring that blood and body parts are handled appropriately to prevent contamination. It is indicative of the evolving understanding of animal welfare in India, recognizing that even religious practices cannot justify cruelty.The court notes that any custom, tradition, or religious practice must be evaluated against constitutional principles rather than historical or cultural acceptance. In this regard, the court refers to Article 13 of the Indian Constitution, which clearly states that all laws inconsistent with or in derogation of the fundamental rights shall be void. The clause explicitly includes customs and usages within the definition of "law," thereby empowering the judiciary to strike down religious practices that contravene fundamental rights, including the right to life and dignity. It draws parallels with earlier rulings where the preservation of human dignity and welfare was prioritized over traditional practices. In N. Adithayan v. Travancore Devaswom Board (2002) 8 SCC 106, the court held that any custom or tradition, even if long-standing, cannot be considered a source of law if it violates human dignity or contravenes constitutional principles³⁷

The Bench also examines whether animal sacrifice, as performed in certain temples, constitutes an essential religious practice. The State argued that such sacrifices are authorized under the document of merger between the King of Tripura and the Government of India and are part of the Tantrik worship method of the “Dash Maha Vidya,” a set of practices deemed integral to certain Hindu rituals. However, the court found no agreement of merger or other substantive legal documents placed on record by the State to substantiate this claim. Furthermore, the petitioner presented a counter-argument by producing records from a meeting held in 1982 concerning temple management in Tripura, which made no reference to animal sacrifice as an essential practice, thus weakening the State’s position.³⁸

In determining what constitutes an essential religious practice, the court reaffirmed the principles established in cases such as Shirur Mutt (1954 SCR 1005), where it was held that the determination of what practices are essential to a religion falls within the purview of the courts, which must decide such matters with reference to the tenets of the religion itself and the community’s perception³⁹. However, these practices must still conform to public order, morality, and health standards as outlined in Articles 25 and 26 of the Constitution, thus it delineates a clear boundary between religious freedom and the obligation to uphold constitutional values, stating that no religious act, irrespective of its claimed sanctity, can be immune from judicial scrutiny.

One of the core arguments advanced in the judgment is the idea that public morality and human dignity must take precedence over religious customs, especially when these customs inflict harm. The court draws a critical distinction between personal beliefs and public law, emphasizing that actions within religious contexts that cause shock, violate public decency, or disturb societal peace cannot be shielded under the guise of religious freedom. This aligns with the court’s broader jurisprudence that underscores the Constitution’s role in safeguarding not just individual rights but also the collective conscience of society.

When Court touches upon the historical context of animal sacrifice, It notes that while certain practices may have been integral to temple rituals in ancient times, their continuation in the modern era poses ethical and legal dilemmas. The court rejects the notion that religious practices are static, advocating instead for an interpretation that allows customs to evolve in tandem with societal progress and contemporary legal standards.

In Hanif Quareshi's case, the court ruled that both directive principles and fundamental duties must be considered when evaluating legal restrictions on fundamental rights.

No religion mandates inflicting unnecessary pain or suffering on animals. Which religion condones physical or mental harm to animals? Which religion discourages compassion, care, or humane treatment of animals?

While Answering above questions, The court examined documents on Tripura's history and found no textual evidence supporting animal sacrifice as obligatory in Mata Tripureswari temple's puja. While animal sacrifice was mentioned, its connection to essential religious practice was unclear. Human sacrifice, once prevalent, was prohibited 200 years ago. Valuing human life led to this change. ⁴⁰Similarly, banning animal sacrifice is logical, as both human and animal life are legally protected.

Jamatia, Noatias, and Riangs share a common religion, worshiping gods of fire, water, forest, and earth. The Festivals of Harvest such as Garia, Mamita , Nakri and ker puja had usage of Animal sacrifices were part of their rituals, ⁴¹It is prescribed in the tradition as must requirement as this practices is essential to their faith. However, Importance does not equate to essentiality. Still the Court make observance that none of the recognized works on Hinduism or Shaktism mention animal sacrifice as an essential practice. Mata Tripureswari Temple which is one of 51 Shakti pithas, has no connection to Tripura's Maharajas but is linked to Sati's lineage. Most Shakti pithas do not practice animal sacrifice.⁴²Although animal sacrifice has been traditionally practiced for 500 years, there is no scriptural or textual evidence supporting its essentiality to the religion. Antiquity alone cannot justify its continuation.

The Court declared that practice of animal sacrifice does not satisfy the test of “ Essential religious practice” Test and thus issued the following directives:

Directives to the State Government:

1. Prohibit animal sacrifice in all temples within the state, including the Mata Tripureswari temple. (Para 45)

2. Frame rules and regulations to regulate temple administration and prevent animal sacrifice. (Para 46)

3. Establish mechanisms for monitoring and enforcing animal welfare laws. (Para 47)

4. Promote public awareness about animal welfare and the illegality of animal sacrifice. (Para 48)

Directives to Temple Authorities:

1. Ensure that no animal sacrifice takes place within temple premises. (Para 41)

2. Promote animal welfare and prevent cruelty. (Para 42)

3. Guidelines for Alternative Methods:

4. Encourage alternative methods of worship, such as symbolic sacrifice or vegetarian offerings. (Para 38)

5. Promote and support alternative methods that do not involve animal sacrifice. (Para 39)

Other Directives:

1. The state government must consider the directives principles and fundamental duties while assessing the reasonableness of legal restrictions placed upon fundamental rights. (Para 98)

2. The state government must ensure that no harm or cruelty is inflicted on animals in the name of religion. (Para 99)

VI. Criticisms

1. The court's analysis appears to dismiss longstanding customary practices without fully engaging with their significance in the lives of the communities involved. Customary laws and traditions often reflect deeply held beliefs and practices that have evolved over centuries. By narrowly focusing on scriptural or textual evidence, the judgment fails to adequately consider the lived experiences and historical context of the communities that practice animal sacrifice.

2. It does not sufficiently appreciate the historical and cultural context of animal sacrifice in the specific religious and regional traditions discussed. The historical accounts and the evolution of practices over time are important in understanding the context in which these practices occur. Customary practices, even if they are not explicitly documented in religious texts, may hold significant cultural and spiritual value for the community.

3. The court's approach may undermine the role of customary laws in maintaining social cohesion and cultural identity. Legal restrictions imposed without considering the customary context can lead to cultural erosion and alienation of communities whose practices are integral to their identity. The judgment’s emphasis on constitutional morality and reform should not disregard the principle of respecting and accommodating diverse customary practices.

4. The judgment lack evidence of engagement with or consultation of the communities directly affected by the legal restrictions. Effective legal adjudication, particularly in matters involving customary laws, requires a thorough understanding of the perspectives and practices of the communities involved. Without such consultation, the court's decision may come across as dismissive of the community’s voice and traditions.

5. While constitutional morality is crucial, it must be balanced with respect for customary rights and practices. The judgment could have explored ways to reconcile constitutional values with customary practices rather than imposing a blanket ban. This approach would demonstrate a more nuanced understanding of the interaction between legal reforms and customary traditions.

VII. Conclusion

The court’s findings reject the State’s defense of animal sacrifice as an essential religious practice, citing a lack of substantive evidence and legal justification. The court emphasizes that the burden of proof rests on those claiming the essential nature of a religious practice, and in the absence of concrete evidence, the practice cannot be accorded legal protection. The ruling underscores the court’s commitment to upholding constitutional morality, rejecting outdated and harmful customs, and ensuring that religious freedom is exercised within the bounds of public order and human dignity. It sets a progressive interpretation of constitutional provisions, prioritizing ethical considerations and human welfare over rigid adherence to tradition. By affirming that no custom, however deeply rooted, can override constitutional mandates, the court reasserts its role as the guardian of fundamental rights and moral integrity within Indian society. This approach not only protects individual freedoms but also ensures that societal practices evolve in line with contemporary standards of justice, equality, and compassion.

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Footnotes

1. Author is a student at K.L.E Law College, Bengaluru, Karnataka, India.

2. Baxi. Upendra. 2013. The Future of Human Riaghts. Oxford University Press. ↩

3. Manikya dynasty is the ruling princely dynasty of Tripura . ↩

4. The ancient religion of Tripuri Community. Wa means Bamboo Thop means nest. According to this cult, it revered to bamboo as the source of divinity and human beings make their ties with illusion like nest . ↩

5. Tibeto mongoloid are the anthropological set of people belonging to the Tibet and Mongolian Origins. ↩

6. Indigeneous people of Tripura are called as Tripuri or Tiprasa in Kikborok dialect. ↩

7. Anglo version of word Tripura used during British Raj. ↩

8. Jamatia Customary laws Act 2017 ↩

9. Ancient kingdom reffering to the state of Tripura ↩

10. Chronicles Of Kings recorded by Kailash Ch. Singha is a book based on the records and documentation of Royal princes of Tripura ↩

11. Hutchinson R. H. Shyed Chittagong hill tracts 1905 ↩

12. Chittagong is a city in Bangladesh which is once part of ancient kingdom of Tripura ↩

13. One of the 51 shakti peetha as per Hindu mythology ↩

14. Hindu Scripture on Shakti ↩

15. Ancient text on shakta sect 12- 13^th CE ↩

16. Fourteen Gods are the traditional indigenious deities of the royal family being revered since ages before installation of Tripureshwari temple. It has history from 7^th C.E ↩

17. The Art of Wisdom as per Hindu scriptures. ↩

18. Animal Sacrifice in Sanskrit is called bali daan ↩

19. Text on yogi practices dating back to 12^th C.E Koch Bihar and Assam ↩

20. Part III(Fundamental Rights) ↩

21. Part IV (Directive Principles of the state Policy) ↩

22. Part IV-A(Fundamental Duties) ↩

23. Animal Welfare Board V A Nagaraja 2014 7 SCC 547 ↩

24. Tamil Nadu V Animal Welfare Board of India 2017 2 SCC144. ↩

25. Ms. R. Menaka Gandhi V. Union Of India 1978 1 SCC 248 ↩

26. The Commissioner, Hindu Religious Endowments, Madras V. Sri Lakshmindra Thirtha Samiar of Sri Shirur Mutt AIR 1954 SC 282. ↩

27. Ratilal panchand Gandhi V. State of Bombay AIR 1954 SC 388 ↩

28. Sardar Syendra Taher Saifuddin Sahef V. State of Bombay AIR 1962 SC 853 ↩

29. (1996)9 SCC 548 ↩

30. Indian Young Lawyers association v. State of Kerala (2018) 13 SCALE 75 ↩

31. Navtej Singh Johar v. Union of india 2018 10 SCC 1; NCT of Delhi v. Union of India 2018 8 SCC 501 ↩

32. Adi Saiva sivachariyargal Nala Snagam v. Government of Tamil Nadu 2016 2 SCC 725 ↩

33. Mohd. Hanif Qurashi v, State of Bihar AIR 1958 SC 731 ↩

34. Riju Prasad sarma v. state of Assam 2015 9 SCC 461 ↩

35. Shayara Bano v. union of India AIR 2017 9 SCC 1 ↩

36. Indian Young Lawyers association v. State of Kerala (2018) 13 SCALE 75 ↩

37. N. Adithayan v. Travancore Devaswom Board (2002) 8 SCC 106 ↩

38. Minutes of meeting 18June 1982 ↩

39. SCR 1005 ↩

40. Tagore Rabidranath, Rajarshi 1917 ↩

41. The Imperial Gazetteer of India ↩

42. Shastri Biswanarayan 1982 yogini Tantra delhi Bharatiya Vidya Prakashan ↩