It is undoubtedly most heartening to note that while according the paramount esteem to Dr BR Ambedkar, the Madurai Bench of the Madras High Court in a most learned, laudable, landmark, logical and latest judgment titled G Rajesh @ Rajesh Kumar Vs State of Tamil Nadu in Crl.O.P.(MD) No.22813 of 2025 that was reserved on 27.02.2026 and then finally pronounced on 30.04.2026 has directed the Tamil Nadu government to introduce lessons on Dr BR Ambedkar in the social science curriculum for students from classes III to X. This must be definitely done at a national level in my personal opinion as Dr BR Ambedkar is the founding father of our Constitution and whose contribution in the creation of the Constitution has just no parallel. Interestingly enough, the directions came in a petition that had been filed to quash criminal proceedings arising from a 2018 incident in Sivagangai district when the accused as alleged by prosecution had torn a poster of Dr BR Ambedkar during his birth anniversary celebrations, urinated on it and circulated a video of the act on Whatsapp.
At the very outset, this brief, brilliant, bold and balanced judgment authored by the Single Judge Bench of the Madurai Bench of Madras High Court comprising of Hon’ble Mrs Justice L Victoria Gowri sets the ball in motion by first and foremost putting forth in para 1 that, “The present Criminal Original Petition, though ostensibly one for quashment on the basis of compromise, raises concerns of far greater constitutional and social significance. The incident which gave rise to the prosecution is not a mere altercation between private individuals, nor is it a dispute concerning purely personal rights. It concerns an act alleged to have been committed against the image and memory of Dr. B.R. Ambedkar, one of the principal architects of modern India, the Chairman of the Drafting Committee of the Constitution, and a statesman whose intellectual labour, moral courage and relentless commitment to social justice helped shape the democratic conscience of this Republic.”
As we see, the Bench then observes in para 2 that, “This Court is therefore called upon to decide not merely whether a criminal proceeding can be brought to a close on account of a subsequent settlement, but also how the law ought to respond when an act born out of ignorance, prejudice or insensitivity touches upon the constitutional values embodied by a national leader of unparalleled stature. The exercise of jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, must therefore be informed not only by precedent on compromise quash petitions, but also by the Court’s solemn obligation to uphold constitutional morality, social harmony and civic education.”
In hindsight, the Bench then points out in para 3 that, “This matter has, therefore, been dealt with by this Court in a manner which is not merely adjudicatory, but also reformative. The order earlier passed on 19.12.2025 was consciously structured to test whether remorse expressed by the petitioners was genuine, whether they were willing to transform ignorance into awareness, and whether their repentance was real and meaningful. On the subsequent date of hearing, namely 23.01.2026, this Court verified such compliance in substance and not in form, and only thereafter proceeded to consider the compromise and the prayer for quashment.”
While elaborating on prosecution case, the Bench then states in para 4 that, “The prosecution case, in brief, is that the third respondent/de-facto complainant, one Amuthan @ Chithiravelu, is the Town Secretary of Viduthalai Siruthai Katchi, Devakottai. According to him, while commemorating the birthday of Dr. B.R. Ambedkar, posters bearing the photograph of Dr. Ambedkar were pasted at Pulikuthi Bus Stand.”
To put things in perspective, the Bench then envisages in para 5 that, “It is alleged that the first petitioner, namely G. Rajesh @ Rajeshkumar, tore one such poster and urinated upon it. The prosecution further alleges that the second petitioner, namely S. Vijay @ Vijayakumar, videographed the said act and thereafter circulated the video in a WhatsApp group by name “Nallava Boys Group”.”
As it turned out, the Bench enunciates in para 6 that, “On the basis of the complaint lodged by the de-facto complainant, the respondent police registered a First Information Report in Crime No.25 of 2018 on 14.04.2018 for the offence under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. Upon completion of investigation, final report came to be laid, culminating in Spl.S.C.No.8 of 2020 on the file of the learned Additional District and Sessions Judge, Exclusive Court for Trial of PCR Act Cases, Sivagangai.”
As things stands, the Bench specifies in para 7 stating that, “The petitioners have now approached this Court seeking quashment of the said proceedings on the basis of a Joint Compromise Memo entered into between themselves and the de-facto complainant.”
Do note, the Bench notes in para 9 that, “The Joint Compromise Memo dated 17.11.2025 discloses that the parties have voluntarily settled their dispute. It records that, during the pendency of trial, elders intervened, both sides sat together, and all issues came to be amicably resolved. It also records that the de-facto complainant has no objection for quashing the criminal proceedings against the petitioners.”
While taking a most pragmatic stand, the Bench then points out in para 10 that, “Since the offence alleged arises under a special enactment intended to protect vulnerable communities from indignity and oppression, this Court did not consider it appropriate to mechanically record the compromise and immediately terminate the proceedings. Instead, the Court deemed it necessary to examine whether the settlement was genuine, whether the petitioners had understood the gravity of their conduct, and whether the apology tendered by them was born out of real introspection or was merely tactical.”
Do also note, the Bench then notes in para 11 that, “When the matter first came up for hearing on 19.12.2025, this Court took note of the compromise entered into between the petitioners and the third respondent/de-facto complainant. However, this Court was also informed that the Government had already paid compensation of Rs.50,000/- to the de-facto complainant under the statutory scheme applicable to offences under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.”
Do further note, the Bench then notes in para 12 that, “Since the criminal case itself was sought to be terminated on the basis of a compromise, this Court directed the third respondent to return the said compensation by way of demand draft drawn in favour of “Adi Dravida Welfare, District Collectorate, Sivagangai District” on or before the next date of hearing.”
Further, the Bench discloses in para 13 that, “This Court thereafter enquired the petitioners as to whether they knew who Dr. B.R. Ambedkar was. Their response revealed that, though they were vaguely aware that he was a legal luminary, they had no real understanding of his life, his scholarship, his role in the making of the Constitution, or his contribution to the liberation of the oppressed and the democratization of Indian society.”
Quite revealingly, the Bench then observes in para 14 that, “That disclosure was, to this Court, deeply revealing. It demonstrated that the alleged act, whether born out of malice or immaturity, was at the very least sustained by ignorance of a colossal order. Dr. B.R. Ambedkar cannot be viewed through the narrow prism of caste sentiment alone. He belongs to the constitutional soul of India. To insult his image is not merely to offend a section of people; it is to exhibit indifference towards the very values of justice, liberty, equality and fraternity on which the Republic is founded.”
Be it noted, the Bench notes in para 15 that, “This Court therefore considered it necessary that the petitioners should not escape the criminal process without first undergoing a meaningful encounter with the life and thought of Dr. B.R. Ambedkar. Accordingly, by order dated 19.12.2025, each of the petitioners was directed:
(i) to purchase 101 books each in Tamil on the life history of Dr. B.R. Ambedkar;
(ii) to first read the book themselves and retain one copy each;
(iii) to distribute the remaining 100 copies each to students studying in the 11th and 12th Standards in Murugappa Government Higher Secondary School, T. Kallupatti, and if books remain, to distribute them to students in lower classes beginning from 10th Standard onwards;
(iv) to obtain acknowledgment from the Headmaster of the said school as proof of compliance;
(v) to read the entire book and remain prepared for an oral test before this Court, so that the Court could satisfy itself that they had truly understood the nobility and contributions of Dr. B.R. Ambedkar; and
(vi) to pay costs of Rs.5,000/- each to the credit of the Adyar Cancer Institute, Chennai.”
Furthermore, the Bench then reveals in para 17 that, “When the matter was taken up on 23.01.2026, both petitioners appeared in person before this Court. They produced materials evidencing compliance with the order dated 19.12.2025. Proof was furnished regarding purchase and distribution of books, acknowledgment from the Headmaster of the concerned school, and payment of costs to the Adyar Cancer Institute.”
Plainly speaking, the Bench points out in para 18 that, “This Court did not stop with documentary compliance. True compliance with the spirit of the earlier order could not have been tested merely by receipts or acknowledgments. The purpose of the direction was reformative and educative. Therefore, this Court conducted an oral test in camera for both petitioners in relation to the life history, scholarship, public service and constitutional contributions of Dr. B.R. Ambedkar.”
Truth be told, the Bench then lays bare in para 19 disclosing that, “In the said oral test, both petitioners vigilantly participated. They were each asked as many as thirty questions pertaining to the life and work of Dr. Ambedkar. They answered the questions satisfactorily and demonstrated that they had not merely purchased and distributed books as a ritualistic act, but had in fact read and understood the substance of the text.”
It is worth noting that the Bench notes in para 20 that, “This Court was fully satisfied, upon interacting with the petitioners, that the petitioners, aged about 26 and 29 years respectively, had undergone a genuine process of reflection. Both petitioners, with visible shame and remorse, expressed regret for their ignorance and sought pardon. Their demeanor before this Court was not defiant; it was penitential. Their repentance appeared real, and their transformation was evident.”
It would be instructive to note that the Bench hastens to add in para 39 that, “It is therefore appropriate to hold that the present case falls within that rare category where the ends of justice would be better served by terminating the proceedings, not because the act alleged is inconsequential, but because the corrective purpose of law has already been substantially achieved.”
It would also be instructive to take into account that the Bench underscores in para 45 stating that, “This Court therefore considers it necessary to remind the State of Tamil Nadu that constitutional literacy is not an ornamental aspiration. It is part of the State’s social responsibility. A welfare State cannot confine itself to administration and infrastructure while neglecting civic education, constitutional memory and social ethics.”
Most commendably, the Bench points out in para 46 that, “The school system must not teach the Constitution merely as a set of dry institutional facts. It must teach the constitutional journey of India through the lives of those who shaped it. Among them, Dr. B.R. Ambedkar occupies a place of singular eminence. To know him is to understand why the Constitution insists upon equality. To study him is to understand why democracy must be social before it can remain political. To remember him is to remember that the Republic is a moral project, not merely a territorial arrangement.”
While striking the right chord, the Bench then holds in para 47 that, “In that view of the matter, this Court deems it appropriate to suo motu implead the Chief Secretary to the State of Tamil Nadu and the Principal Secretary to Government, School Education Department, as respondents 4 and 5 in this Criminal Original Petition, for the limited purpose of issuing broader directions in public interest.”
To be sure, the Bench then also directs in para 48 that, “Registry is directed to carry out the necessary amendment in the cause title.”
Most significantly, the Bench encapsulates in para 49 what constitutes the cornerstone of this notable judgment postulating precisely that, “Respondents 4 and 5 are directed to take necessary policy steps, in accordance with law and administrative feasibility, to introduce appropriate lessons in the Social Science curriculum in the State syllabus, for students from Class III to Class X, on:
(i) the role of Dr. B.R. Ambedkar as Chairman of the Drafting Committee of the Constitution of India;
(ii) his contribution to the constitutional vision of justice, liberty, equality and fraternity;
(iii) his role in the freedom movement and in democratic nation-building; and
(iv) his scholarly achievements in the fields of economics, law and social thought.”
In addition, the Bench then directs and holds in para 50 that, “The State shall endeavour to give effect to such curricular inclusion from the academic year 2027–2028, subject to pedagogical planning, academic structuring and compliance with all applicable norms. The purpose of the direction is not political glorification, but constitutional education.”
Most remarkably, the Bench expounds in para 51 holding that, “The State must recognise that social harmony cannot be maintained merely by criminal prosecution after damage is done. It must be cultivated proactively through education, awareness and ethical citizenship. The true tribute to Dr. Ambedkar lies not merely in statues and ceremonies, but in ensuring that every child in this State knows why he matters to India.”
Frankly speaking, the Bench in epilogue then directs and holds in para 52 that, “Courts are often required to decide whether a prosecution must continue or end. But there are rare occasions when the Court must do something more: it must convert a moment of social fracture into an occasion for constitutional reaffirmation. The present case is one such occasion.”
Most rationally, the Bench observes in para 53 that, “The petitioners came before this Court as young men accused of a deeply insensitive act. They leave this Court not with an unexamined absolution, but after having been compelled to read, learn, distribute, reflect and repent. The de-facto complainant, for his part, has chosen reconciliation. The law, in the peculiar facts of this case, has therefore achieved something beyond punishment; it has achieved understanding.”
On a bright note, the Bench exudes confidence holding in para 54 that, “This Court hopes that the petitioners will carry the memory of these proceedings not as a mark of humiliation, but as a lesson in citizenship. It also hopes that the State will heed the larger message embedded in this case: that democracy survives not only by institutions of governance, but by institutions of learning; not only by penal law, but by civic culture; not only by order, but by moral education.”
What’s more, the Bench then underscores in para 55 holding unequivocally that, “Though this Court is fully aware that it is not for the judiciary to command the State to adopt a particular policy or to dictate, as a matter of compulsion, what must find place in the curriculum of school education, this Court is nevertheless constrained to emphasise that the constitutional value of fraternity cannot be left to chance or to the uncertainties of social transmission. The seeds sown by our Constitution, particularly those of justice, liberty, equality and fraternity, must be consciously nurtured if they are to endure. The time has come for the State to recognise that constitutional literacy is itself a component of social responsibility. For the sake of future India, and for the shaping of young Indians as informed, humane and constitutionally conscious citizens, such measures can no longer be deferred.”
Finally and resultantly, the Bench then concludes by directing and holding in para 56 that, “In the result, this Criminal Original Petition is allowed on the following terms:
(i) The proceedings in Spl.S.C.No.8 of 2020 on the file of the learned Additional District and Sessions Court for Exclusive Trial of PCR Act Cases, Sivagangai, are hereby quashed and the Criminal Original Petition is allowed.
(ii) The Joint Compromise Memo dated 17.11.2025 shall form part and parcel of this order.
(iii) The compliance already recorded by this Court in respect of the order dated 19.12.2025, including return of compensation, distribution of books, payment of costs, and satisfactory completion of oral interaction before this Court on 23.01.2026, shall stand incorporated into this order.
(iv) The Chief Secretary to the State of Tamil Nadu and the Principal Secretary to Government, School Education Department, are suo motu impleaded as respondents 4 and 5, and the directions contained in paragraphs 49 to 53 above shall be complied with in letter and spirit.
(v) Registry shall carry out the amendment in the cause title.
(vi) Post the case for compliance on 21.01.2027 by the 4th and 5th respondents. Respondents 4 and 5 are directed to file an elaborate report as to the steps taken in complying the directions passed by this order on 21.01.2027. ”
In conclusion, we thus see that the Single Judge Bench of Madurai Bench of Madras High Court comprising of Hon’ble Mrs Justice L Victoria Gowri in its judgment on April 30 has directed the Tamil Nadu government to introduce lessons on eminent jurist and key architect of the Indian Constitution – Dr BR Ambedkar on the social science curriculum for students from Classes III to X. It was also directed most rationally by the Bench that the curriculum should include Dr Ambedkar’s role as Chairman of the Drafting Committee of the Constitution, his contributions to constitutional values like justice, liberty , equality fraternity; his participation in the freedom movement and his scholarly work in law, economics and social theory.
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