Right to Sleep and it's Judicial endorsement
Sleeping forms an essential ingredient for healthy human existence and well being. The deprivation of Sleep to a person is infringement of his Right to live in healthy environment. As all other rights, this right is also subjected to reasonable restriction under procedure established by Law. It can be infringed by Noise or other disturbance. Various Legislations recognize Noise as a form of Pollutant and thus is under the umbrella of Noise Pollution (Regulation and Control) Rules, 2000 and other environment protection Acts. But this does not necessarily infer this is absolute. Every person in this universe is separate in its identity. What is melancholy rhyme for one can be a disaster for other. Similarly a person may have specific sensitivity towards sound of even low decibels. But these sound producing sources such as automobiles, trains and industries should be shunned down. They are important for human development too. No right is inferior or exterior, higher of lower to its peer right. The reasonable restrictions are imposed on the right which has an overriding effect on other right without any reasonableness. This paper discusses in length the various issues pertaining to Right to Sleep.
Sleep is a biological imperative. It is not negotiable. Any degree of sleepiness will impair performance and mood. Sleep is when our bodies are at their busiest: While our waking minds go on autopilot, some of our bodies’ most sophisticated mechanisms rev up to do the hard work involved in repairing and maintaining nearly every aspect of our physiology and psychology.
Right to Sleep: A Constitutional Right
Under Article 19(1) (a), read with Article 21 of the Constitution of India, the citizens have a right of a decent environment and they have a right to live peacefully, right to sleep at night and to have a right to leisure which is all necessary ingredients of the right to life guaranteed under Article 21 of the Constitution. People of India have a right to sleep and leisure. Disruption or disturbance in sleeps creates mental stress, deficient in working efficiency and other things.
In Sayeed Maqsood Ali V/s State of Madhya Pradesh, the Hon’ble High Court of Madhya Pradesh held that:
“Every citizen is entitled under Article 21 of the Constitution to live in a decent environment and has the right to sleep peacefully at night. Not for nothing it has been said sleep is the best cure for waking troubles and the sleep of a labouring man is sweet. Sleep brings serenity. Lack of sleep creates lack of concentration, irritability and reduced efficiency. It cannot be lost sight of that silence invigorates the mind, energises the body and quitens the soul. That apart, the solitude can be chosen as a companion by a citizen. No one has a right to affect the rights of others to have proper sleep, peaceful living atmosphere and undisturbed thought. No citizen can be compelled to suffer annoying effects of noise as that eventually leads to many a malady which includes cardio vascular disturbance, digestive disorders and neuro psychiatric disturbance.”
Laboratory studies made by monitoring electroencephalographic (EEG) responses and changes in neurovegetative reactions during sleep, show that disturbance of sleep becomes increasingly apparent as ambient noise levels exceed about 35 db (A) Leq. Noise produces different reactions along the hypothalamohypophyseal-adrenal axis, including an increase in adenocorti-cotropic hormone (ACTH), affecting sympathetic division of the autonomic nervous system.
Some evidence suggests that levels of the chemical adenosine in the brain play an important role. Blood levels of adenosine rise continually during waking hours, creating an urge to sleep that grows increasingly difficult to resist. During sleep, levels of adenosine decrease. Drugs like caffeine disrupt this process by blocking the adenosine receptor. Although these drugs make you more alert in the short run, they don’t erase your sleep debt.
Dr. Alexandros N. Vgontzas, says:
“If you lose one night of sleep, your mental performance is like you’re legally drunk, if you don’t sleep well, you can develop something almost like a prediabetic condition — an ineffective use of insulin Stress leads to lack of sleep. Lack of sleep leads to increased stress. Stress can lead to overeating. People eat to reduce anxiety. We’ve seen this effect even in people who reduce their sleep from eight hours to six. You develop a condition of low-grade inflammation, and we know that low-grade inflammation is a pathway to cardiovascular problems and decreased longevity”.
In study after study, sleep researchers have found that good sleep sets up the brain for positive feelings. When we don’t have enough sleep, we have a sour view of circumstances: We are more easily frustrated, less happy, and short tempered, less vital.
The effect of bad night sleep relied upon by Hon’ble Calcutta High Court (as now being referred to as Kolkata High Court) in Burrabazar Fire Works Dealers Association & Ors. V. The Commissioner of Police & Ors as highlighted by an eminent scientist in this field in her article in British Medical Journal, in which it was stated that noise can have positive effects on health. The effect of bad night sleep includes mood change, reduce cardiovascular performance and poor performance at intellectual and mechanical tasks and it was further observed, a recent review of research into noise and sleep recommends that sound at night in sleeping quarters should not exceed 45 dB(A).
Interference with rest or sleep and the factor associated with it includes lack of concentration, irritability reduced efficiency and is one of the most obvious and annoying effects of noise. Sleep is a physiological necessity and therefore, health may be adversely affected by insufficient sleep. Apart from health, apart from deafness it affects the digestive system, cardiovascular disturbance in cardiovascular system (circular) etc.
Noise: A Pollutant
Noise as defined by Dr. Christopher N. Penn "a number of tonal components disagreeable to man and intolerable to him because of the discomfort fatigue agitation and in some cases pain it causes.”
In Forum, Prevention of Environment and Sound Pollution v. Union of India,
Your Lordships observed:
“Noise has both auditory and non-auditory effects depending upon the intensity and the duration of the noise level. It affects sleep, hearing, and communication, mental and physical health. Noise can disturb our work, rest, sleep, and communication Disturbance of sleep. Noise intrusion can cause difficulty in falling asleep and can awaken people who are asleep. Not only might there be harmful consequences to health during the state of alertness, but research also suggests effects may occur when the body is unaware or asleep.”
The Air (Prevention and Control of Pollution) Act. 1981 (14 of 1981) defines Air Pollution and Air Pollution in sections 2(a) and 2(b) respectively to mean:
2(a) Air Pollutant means any solid, liquid or gaseous substance 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;
2(b) Air Pollution means the presence in the atmosphere of any air pollutant.
Noise is a pollutant which causes material injury to the rights of an individual. It contaminates environment, causes nuisance and affects the health of a person and therefore, it exceeds a reasonable limit, offends Article 21 of the Indian Constitution. A bye-law of a Municipality requiring permission for using a loudspeaker does not infringe Article 19(1)(a). The World Health Organization has fixed 45 decibels as the safe noise level for a city. By the international standards, a noise level up to 64 decibels is considered tolerable.
As regards noise pollution, it simply connotes unwanted sound in the atmosphere. It is unwanted because it lacks the agreeable amicable quality. Noise is, Therefore, sound, but it is pollution when the effects of sound become undesirable. The sweetest music, if it disturbs a person who is trying to concentrate or to sleep, is noise to him, just as the sound of a pneumatic riveting hammer is noise to nearly everyone. Noise effects human life in many ways. If affects sleep, hearing, communication, mental and physical health and make men peaceless. It may even lead to the madness of people.
In Free Legal Aid Cell Shri Sugan Chand Aggarwal Alias Bhagat Ji v. Govt. of NCT of Delhi and Others, Your Lordships’ of Hon’ble Delhi High Court Observed:
“Noise is a pollutant which causes material injury to the rights of an individual. It contaminates environment, causes nuisance and affects the health of a person and therefore, it exceeds a reasonable limit, offends Article 21 of the Indian Constitution. A bye-law of a Municipality requiring permission for using a loudspeaker does not infringe Article 19(1)(a). The World Health Organization has fixed 45 decibels as the safe noise level for a city. By the international standards, a noise level up to 64 decibels is considered tolerable.
As regards noise pollution, it simply connotes unwanted sound in the atmosphere. It is unwanted because it lacks the agreeable amicable quality. Noise is, Therefore, sound, but it is pollution when the effects of sound become undesirable. The sweetest music, if it disturbs a person who is trying to concentrate or to sleep, is noise to him, just as the sound of a pneumatic riveting hammer is noise to nearly everyone. Noise effects human life in many ways. If affects sleep, hearing, communication, mental and physical health and make men peaceless. It may even lead to the madness of people.”
Right to Life and Liberty vs Right to Freedom of Speech and Expression
Life is a glorious gift from God. It is the perfection of nature, a masterpiece of creation. It is majestic and sublime. Human being is the epitome of the infinite prowess of the divine designer. Great achievements and accomplishments in life are possible if one is permitted to lead an acceptably healthy life. It has been said "life is action, the use of one's powers" and powers one can use if he has real faith in life. The term 'life' as employed under Article 21 of the Constitution of India does never mean a basic animal existence but conveys living of life with utmost nobleness and human dignity - dignity which is an ideal worth fighting for and worth dying for.
Life takes within its fold "some of the finer graces of human civilization which makes life worth living". Right to live in its ambit includes right to health and health gives a serene and halcyon signification to life. It has been said that preservation of health is a duty and as per Herbert Spencer, "few seems conscious that there is such a thing as physical morality". While speaking about health thus spoke Izaak Walton....... "for health is the second blessing that we mortals arc capable of; a blessing that money cannot buy".
Reverence for life is a fundamental principle of morality and a life without good health is denial of life. The human body is regarded as the house of creative intelligence. The health of an individual enhances the quality of the collective and in a welfare state it is the bounden obligation of the State to see that people remain in a healthy society. It is to be borne in mind that even in the international sphere emphasis is laid on proper health and a right is enshrined providing security against sickness and disablement under Article 25 of the Universal Declaration of Human Rights. I have adverted to health and life as in the case at hand this Court is concerned with noise pollution which causes many a serious disorders and creates a dent in the fabric of society. One of the eminent author in his book has categorically stated that noise is undoubtedly psychologically and physiologically harmful as an invisible and insidious form and once hearing has been damaged by noise it can scareely ever be restored to wholeness.
The Hon’ble Apex court in Kharak Singh v. State of U.P while defining the meaning of ancillary visits at nights held that
“Intrusion into the residence of any person and knocking at his door with the disturbance to his sleep and ordinary comfort necessarily violates his freedom of Right to move freely (under 19(1) (d)) and also is "a deprivation" of his "personal liberty" guaranteed under Art. 21.”
Your Lordships while explaining the scope of words "life" and "liberty" quoted the paragraph from a U.S. judgment of Field.J which inter- alia stated that “Live” does not mean mere animal existence and decipher something more than that. The inhibition against its deprivation extends to all these limits and faculties by which life is enjoyed. In continuation of examining the width, scope and content of the expression "personal liberty" in Art. 21, Your Lordships’ another paragraph of a U.S. Judgment of Frankfurter, J. observed that the act of knocking at the door within its own authority is inconsistent with the concept of Human Rights enshrined in basic constitution documents of English speaking people and no commentary of recent history is required to condemn such inconsistent law. In fact is against the very essence of scheme of ordered liberty. The house of everyone is to him as his castle and fortress as well as for his defense against injury and violence as for his repose" and an unauthorized intrusion in to a person’s house is a violation of his common law right which is indeed an ultimate essential feature of ordered liberty. Thus, your Lordships held that domiciliary visits at night by police are volatile to personal life and liberty of an individual and hence the same is unconstitutional.
In Govind vs State of Madhya Pradesh, which was in Pari material to Kharak Singh , Your Lordships held that 'liberty' in Article 21 was comprehensive enough to include privacy also. Your Lordship citing U.S. judgment of inferred that although right to privacy is not explicitly mentioned in Constitution of India, a guarantee of certain areas or zones of privacy does exist under it. Right to privacy is a right to be left alone is an interest which is to be asserted directly and the same should not be derived or asserted from his efforts to protect the interests of others. A man can find his pain, pleasure and satisfaction for life in material things and hence the same should be conferred upon him against the sphere of government where he should be left alone. Although the term privacy includes freedom to live one’s life without state’s interference but in every case such right is not at stake and thus the Court should not use these word as synonymous in every case. The Court held that the power conferred under MP Police Regulations 855 and 856 authorizing the domiciliary visits had the force of law and therefore, be treated as reasonable restriction on the right to privacy
Liberty is not the right to perpetuate licentiousness. It does not sanction intrusion into rights of others. "No one has a natural right to commit aggression on the equal rights of another." The liberties of some could prove to be the end of the liberties of others. The loquacious may silence the meek. Right to be let alone is the beginning of all freedoms. When we force people to listen to another's ideas, we give the propagandist a powerful weapon. One man's lyric may be another's vulgarity." No one has a right to trespass on the mind or ear of another and commit auricular or visual aggression.
In the case of Aditya Thackeray v. Telecom Regulatory Authority of India, the plaintiff contended that sending of SMSs, being a mode of communication, any cap put thereupon would be contrary to the fundamental freedom of speech and expression as envisioned in Article 19(1)(a) of Constitution of India and does not constitute a reasonable restriction within the meaning of Clause (2). The Court while interpreting various Constitutional mandates observed that
“While restrictions in the interest of general public are permissible so far as other Fundamental Rights are concerned, it is not in respect of Fundamental Right of Freedom of Speech and Expression…Right of privacy merely indicates a quality of life. By reason of communication of a message, unless it touches upon obscenity or morality or is otherwise defamatory, does not intrude any home as such”.
The Court held that Right of privacy is undoubtedly a very valuable right. But in a case of this nature those who do not want to be disturbed by telemarketers, need not get themselves registered with "Do Call” Registry.
The Hon’ble Supreme Court in the case of Cooverjee B. Bharucha vs The Excise Commissioner, (Constitution Bench) have held that in order to determine the reasonableness of the restrictions regard must be had to the nature of the business and the condition prevailing in the trade. It is obvious that these factors must differ from trade to trade and no hard and fast rules concerning all traders can be laid down. The right of every citizen to pursue any lawful trade or business is obviously subject to such reasonable conditions as may be deemed by the Governing Authority of the country essential to the safety, health, peace, order and morals of the community.
In Om Birangana Religious Society vs The State And Ors, Hon’ble Calcutta High Court (as now being referred to as Kolkata High Court), observed:
“Freedom of speech and expression guaranteed under Article 19(1) (a) of the Constitution of India includes, by necessary implication, freedom not to listen and/or to remain silent. One cannot exercise his right at the cost and in total deprivation of others' rights. A right cannot be conferred by the authorities concerned upon a person or a religious organization to exercise their rights suspending and/or taking away the rights of others. Freedom of speech is guaranteed to every citizen so that he may reach with the winds of willingness and not coerced unwillingness.
The provisions of Article 25 is subject to the provisions of Article 19(1)(a) of the Constitution. On true and proper construction of the provisions 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.
The citizens have a right to enjoy their lives in the way they like, without violating any of the provisions of the law. A citizen has a right to leisure, right to sleep, right not to hear and right to remain silent. He has also the right to read and speak with others. Use of microphones certainly takes away the right of the citizens to speak with others, their right to read or think or the right to sleep”.
In England and other countries of the world excepting U.K., there is no such constitutional protection and there is no fundamental right as provided by our Constitution and the Constitution of U.K. Our entire legal system is. Based on rights which mean that even the Parliament or the Legislature cannot make any law suspending or interfering with the fundamental rights of the citizens unreasonably. Citizens fundamental rights under Article 19(1)(a) of the Constitution is a very important right so far as the citizens of this country are concerned.
The Central Government made the Noise Pollution (Regulation and Control) Rules, 2000. Rule 5 of this Act reads as under:
"5. Restrictions on the use of loud speakers/public address system:-
(1) A loudspeaker or a public address system shall not be used except after obtaining written permission from the authority.
(2) A loudspeaker or a public address system shall not be used at night (between 10.00 p.m. to 6.00 a.m.) except in closed premises for communication within, e.g. auditoria, conference rooms, community halls and banquet halls.
(3) Notwithstanding anything contained in Sub- rule (2), the State Government may, subject to such terms and conditions as are necessary to reduce noise pollution, permit use of loud speakers or public address systems during night hours (between 10.00 p.m. to 12.00 midnight) on or during any cultural or religious festive occasion of a limited duration not exceeding fifteen days in all during a calendar year.”
A series of cases have been filed before various Courts of India for allowing use of Loudspeakers for religious purposes. The most common contention of these religious institutions are that it is within their right to Religion under Article 25 of the Indian Constitution, to use an Public speaker to practice and propagate their religion. A very important passage pertaining to this issue, was published in Times of India which was duly relied upon by Your Lordships of Hon’ble Apex Court in Forum, Prevention of Environment and Sound Pollution v. Union of India & Others, the relevant portion is produced hereinafter:
"Those who favor the use of loudspeakers plead that it is a devotee's religious duty enjoined by the shastras to make others listen and enjoy the singing of bhajans. Azaan too is necessary to inform others that it is time for namaz, a job assigned to the muezzin of the mosque.
Wait a minute. There were no loudspeakers in the old days. When different civilizations developed or adopted different faiths or when holy books were written to guide devotees, they did not mention the use of loudspeakers as being vital to spread religious devotion. So the use of loudspeakers cannot be a must for performing any religious act. Some argue that every religion asks its followers to spread its teachings and the loudspeaker is a modern instrument that helps to do this more effectively. They cannot be more wrong. No religion ever says to force the unwilling to listen to expressions of religious beliefs. In the Bhagavad Gita, Krishna says to Arjuna:
"This secret gospel of the Gita should never be imparted to a man who lacks penance, nor to him who is wanting in devotion, nor even to him who lends not a willing ear; and in no case to him who finds fault with Me.... He who, offering the highest love to Me, preaches the most profound gospel of the Gita among My devotees, shall come to Me alone; there is no doubt about it" (18.67-68). We are inclined to quote the following passage from Times of India (The Speaking Tree) dated 7.10.2005:
A similar instance is found in Biblical literature. The Gospel according to Saint Luke says: "When Jesus had called the Twelve together, he gave them power and authority to drive out all demons and to cure diseases, and he sent them out to preach the kingdom of God and to heal the sick.
He told them: 'Take nothing for the journey - no staff, no bag, no bread, no money, no extra tunic. Whatever house you enter, stay there until you leave that town. If people do not welcome you, shake the dust off your feet when you leave their town, as a testimony against them'. So they set out and went from village to village, preaching the gospel and healing people everywhere" (9.1-10).”
In Burrabazar Fireworks Dealers Association v. Commissioner of Police, Calcutta, it has been held
"Article 19 of the Constitution of India does not guarantee the fundamental right to carry on trade or business which creates pollution or which takes away that communities safety, health and peace....A citizen or people cannot be made a captive listener to hear the tremendous sounds caused by bursting out from a noisy fireworks. It may give pleasure to one or two persons who burst it but others have to be a captive listener whose fundamental rights guaranteed under Article 19 and other provisions of the Constitution are taken away, suspended and made meaningless....Under Article 19, read withy Article 21 of the Constitution of India, the citizens have a right of decent environment and they have a right to live peacefully, right to sleep at night and to have a right to leisure which are all necessary under Article 21 of the Constitution."
The Supreme Court in Church of God (Full Gospel) in India v/s K.K.R. Majestic Colony Welfare Assn
“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”.
The Fundamental rights belong to human personality, and not to a mechanical device. 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 rights under Article 19 (though they may be useful to man to express his faculties).
In the case of Moulana Mufti Syed Md. Noorur Rehman Barkati and others v. State of West Bengal, wherein it has been held as under:
"None can claim an absolute right to suspend other rights or it can disturb other basic human rights and fundamental rights to sleep and leisure. The argument that the Environmental (Protection) Act, Rules and the Schedule therein are ultra vires under Articles 14 & 25, is wholly misconceived as it had not resulted any discrimination and so far as Sound Pollution is concerned, citizens have a right to be protected against excessive sound under Article 19(1)(a) of the Constitution."
In Acharya Maharajshri Narendera Prasadji Anand Prasadji Maharaj v. The State of Gujarat
After considering the various contentions, the Court observed that "no rights in an organized society can be absolute. Enjoyment of ones' 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."
Ramlila Maidan Incident v/s Home Secretary. The Apex Court passed the verdict after taking ‘suo motu’ cognizance of media reports showing the brutality of police action against the followers of Ramdev who were sleeping. According to the Court, a person cannot be presumed to be engaged in a criminal activity or an activity to disturb peace of mind when asleep. Justice Chauhan opined, ‘To presume that a person was scheming to disrupt public peace while asleep would be unjust and would be entering into the dreams of that person. ‘I am bewildered to find out as to how such declaration of the intention to impose the prohibition was affected on a sleeping crowd.’
In the light of Judicial pronouncements and Judicial Precedents discussed above, I came to the conclusion that Right to Sleep though not explicitly mentioned in the Constitution of India, but is a part of Fundamental Right under Right to life under Article 21. Life is much more than combination of body and Soul. It implicates the physical and mental conditions necessary to keep body and Soul together. Right to life thus includes all the conditions which are minimally essential for Human existence. Sleep, as discussed above, is an essential ingredient to live a healthy and balanced life and therefore Right to life impliedly included Right to Sleep. Thus an inference can be drawn that Constitutional protections present for infringement of Right to life can be taken up in case of deprivation of Right to Sleep. No Doubt every right is not an absolute Right and is subjected to reasonable restriction, but no person can enjoy his right at the cost of another. Nor such overriding rights can be imposed on others. Right to Life is in no way in contradiction to Right o Freedom of Speech and Expression and Right to Freedom of Trade but is subject to reasonable restriction.
# Mark Mahowald, MD, director of the Minnesota Regional Sleep Disorders Center and professor of neurology at the University of Minnesota
# Sayeed Maqsood Ali v. State of Madhya Pradesh & others AIR 2001 MP 220.
# P.A. Jacob v. The Superintendent of Police, Kottayam and anr. AIR 1993 KER 1.
# MD, director of the Sleep Research and Treatment Center at Penn State University in Hershey.
# Dr.William C. Dement and Christopher Vaughan in “The Promise of Sleep” (2000) Dell.
# Burrabazar Fire Works Dealers Association & Ors. v. The Commissioner of Police & Ors AIR 1998 CAL 121.
# Dr.Fiona Godlee (General physician in Cambridge and a Fellow of the Royal College of Physicians)
# Dr.Fiona Godlee, ‘Health effects of obstructive sleep apnoea and the effectiveness of continuous positive airways pressure: a systematic review of the research evidence’ (1997) British Medical Journal at 314:851.
# Available at http://www.bmj.com/content/314/7084/851 Accessed 15 May 2014.
# Christopher N. Penn “Noise Control: The Law and Its Enforcement” (Shaw & Sons: 3rd Edition).
# Forum, Prevention of Envn. and Sound Pollution v. Union of India (UOI) and Ors AIR 2005 SC 3136.
# Office of Noise Abatement and Control, “Noise Effects Handbook”, (U.S. Environmental Protection Agency, 1979).
# Encyclopedia Britannica (Vol. 16, 1968, p. 558)
# Free Legal Aid Cell Shri Sugan Chand Aggarwal Alias Bhagat Ji v. Govt. of NCT of Delhi and Others AIR 2001 Delhi 455.
# Encyclopedia Britannica (Vol. 16, 1968, p. 558).
# Christopher Stephen Kerse 'The Law Relating to Noise' (Oyez Publishing, 1975).
# Sayeed Maqsood Ali v. State of M.P. and others AIR 2001 MP 220.
# Kharak Singh v. State of U.P. & Others AIR 1963 SC 1295.
# Wolf v. Colorado (1949) 338 U.S. 25.
# Murphy, J.
# Semayne's case (1604) 5 Coke 91 : 1 Sm. L.C. 104
# Gobind v. State of Madhya Pradesh & Others AIR 1975 SC 1378.
# Jane Roe v. Henry Wade 410 U.S. 113.
# "The Right to Privacy" by Charles Warren and Louis D. Brandeis See 4 Harvard Law Rev. 193.
# Brandeis, J. said in his dissent in Olmstead v. United State 277 U.S. 438
# “The Wages of Crying Wolf”: A Comment on Roe v. Wade, 82 Yale L.J. 920.
# Cooverjee v. Excise Commissioner and the Chief Commissioner, Ajmer 1 SCR 873
# Om Birangana Religious Society v. The State and Ors (1996) ILR 2 CAL 404.
# Forum, Prevention of Environment and Sound Pollution v. Union of India & Others AIR 2006 SC 348.
# Church of God (Full Gospel) in India v. K.K.R. Majestic Colony Welfare Assn. AIR 2000 SC 2773. 2000 (3) KLT 651 : 2000 (6) SCALE 163.
# P.A. Jacob v. The Superintendent of Police, Kottayam and anr. Supra.
# Acharya Maharajshri Narendera Prasadji Anand Prasadji Maharaj v. The State of Gujarat AIR 1974 SC 2098.
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