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 judgement 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.

Madras High Court Directs Ambedkar Lessons In Schools

This must be definitely done at a national level in my personal opinion, as Dr B.R. Ambedkar is the founding father of our Constitution, and his contribution to the creation of the Constitution has just no parallel.

Background Of The Case

Interestingly enough, the directions came in a petition that had been filed to quash criminal proceedings arising from a 2018 incident in the Sivagangai district when the accused, as alleged by the 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.

Constitutional Significance Of The Judgement

At the very outset, this brief, brilliant, bold and balanced judgement authored by the Single Judge Bench of the Madurai Bench of the Madras High Court comprising the 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.”

Key Takeaways From The Verdict

• The Madras High Court emphasized the constitutional and social importance of Dr B.R. Ambedkar.
• The Court directed the Tamil Nadu government to introduce Ambedkar lessons for Classes III to X.
• The case originated from a 2018 incident involving alleged desecration of Dr Ambedkar’s poster.
• The Court observed that the matter was not merely a private dispute but one involving constitutional values.
• The judgement highlighted Dr Ambedkar’s role as the Chairman of the Drafting Committee of the Constitution.

Constitutional Morality And Quash Petitions

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.”

Key Constitutional Principles Highlighted

• Constitutional morality
• Social harmony
• Civic education
• Judicial responsibility in compromise quash petitions
• Protection of values represented by Dr. B.R. Ambedkar

Court Adopts Reformative Approach

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.”

Focus Of The Court’s Reformative Process

Prosecution Case Background

While elaborating on the 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.”

Background Of The Incident

• Commemoration of Dr. B.R. Ambedkar’s birthday
• Posters displayed at Pulikuthi Bus Stand
• Complaint lodged by Town Secretary of Viduthalai Siruthai Katchi
• Incident linked to alleged insult to Dr. Ambedkar’s image

Allegations Against The Petitioners

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 the name “Nallava Boys Group".

Specific Allegations Recorded By The Court

Registration Of FIR And Investigation

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, the 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.”

Case Progression Timeline

Petition For Quashment

As things stand, 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.”

Basis For Seeking Quashment

• Joint Compromise Memo executed between parties
• Settlement reached during pendency of proceedings
• No objection from de facto complainant
• Request made for quashing criminal proceedings

Joint Compromise Memo Details

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 to quashing the criminal proceedings against the petitioners.”

Important Points In The Compromise Memo

• Voluntary settlement between parties
• Intervention of elders during trial
• Amicable resolution of dispute
• No objection to quashing from complainant

Court Refuses Mechanical Quashing

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.”

Why The Court Examined The Settlement Carefully

Court Observations on Compromise and Compensation

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.”

Direction To Return Compensation Amount

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.”

Court Questions Petitioners About Dr. B.R. Ambedkar

Further, the Bench discloses in para 13 that, “This Court thereafter enquired of 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 democratisation of Indian society.”

Constitutional Values and Dr. Ambedkar’s Legacy

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.”

Court Imposes Educational and Social Conditions

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 to do the following:

• to purchase 101 books each in Tamil on the life history of Dr B.R. Ambedkar;
• to first read the book themselves and retain one copy each;
• 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;
• to obtain acknowledgment from the Headmaster of the said school as proof of compliance;
• 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
• to pay costs of Rs.5,000/- each to the credit of the Adyar Cancer Institute, Chennai.”

Summary of Directions Issued by the Court

Court Satisfaction on Compliance With Earlier Directions

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 the purchase and distribution of books, acknowledgement from the headmaster of the concerned school, and payment of costs to the Adyar Cancer Institute.”

Court Tests Genuine Compliance Beyond Documents

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 acknowledgements. 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.”

Oral Test Conducted on Dr B.R. Ambedkar’s Life and Contributions

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.”

Petitioners Show Remorse and Transformation

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 demeanour before this Court was not defiant; it was penitential. Their repentance appeared real, and their transformation was evident.”

Ends of Justice Better Served by Terminating Proceedings

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.”

Constitutional Literacy Is a State Responsibility

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.”

Importance of Teaching Dr B.R. Ambedkar in Schools

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.”

Chief Secretary and Education Department Impleaded

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.”

Registry Directed to Amend Cause Title

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.”

Directions on Social Science Curriculum in Tamil Nadu

Most significantly, the Bench encapsulates in para 49 what constitutes the cornerstone of this notable judgement, 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:'

Key Takeaways From the Judgment

• The Court emphasized reformative justice over punitive action.
• The petitioners were orally tested on the life and contributions of Dr B.R. Ambedkar.
• The Bench recognized genuine remorse and transformation in the petitioners.
• The Court highlighted the importance of constitutional literacy in schools.
• Directions were issued to Tamil Nadu authorities for curriculum reforms.

Constitutional Education And Social Harmony

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.”

Key Directions Issued By The Bench

Importance Of Social Harmony And Ethical Citizenship

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.”

Court On Constitutional Reaffirmation

Frankly speaking, the bench in the 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.”

Constitutional Values Highlighted By The Court

• Justice
• Liberty
• Equality
• Fraternity
• Constitutional Literacy
• Ethical Citizenship

Law Achieving Understanding Beyond Punishment

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.”

Lesson In Citizenship And Moral Education

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 also by institutions of learning; not only by penal law but also by civic culture; not only by order but also by moral education.”

Constitutional Literacy As Social Responsibility

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.”

Major Takeaways From The Judgment

• Constitutional education is essential for long-term social harmony.
• Courts can promote reconciliation and constitutional values beyond punishment.
• Ethical citizenship must be nurtured through education and awareness.
• Constitutional literacy is linked directly to social responsibility.
• Democracy depends on civic culture, moral education and institutions of learning.

Madras High Court Final Directions In The Case

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) Proceedings Quashed By Court

(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) Joint Compromise Memo To Form Part Of Order

(ii) The Joint Compromise Memo dated 17.11.2025 shall form part and parcel of this order.

(iii) Compliance Directions Incorporated Into 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) Tamil Nadu Government Officials Suo Motu Impleaded

(iv) The Chief Secretary to the State of Tamil Nadu and the Principal Secretary to the 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 Directed To Carry Out Amendment

(v) The registry shall carry out the amendment in the cause title.

(vi) Compliance Report To Be Filed

(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."

Key Directions Issued By The Madras High Court

Dr BR Ambedkar Lessons In Tamil Nadu School Curriculum

In conclusion, we thus see that the single judge bench of the Madurai bench of the Madras High Court, comprising the Honourable Mrs Justice L Victoria Gowri, in its judgement 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 and fraternity, his participation in the freedom movement and his scholarly work in law, economics and social theory.

Topics To Be Included In The Curriculum

• Dr BR Ambedkar’s role as Chairman of the Drafting Committee
• Constitutional values of justice, liberty, equality and fraternity
• Participation in the Indian freedom movement
• Scholarly contributions in law, economics and social theory
• Social justice and constitutional philosophy

Importance Of The Judgment

The judgement assumes immense significance as it emphasizes constitutional education, social justice awareness and the role of Dr BR Ambedkar in shaping modern India. The directions issued by the Madras High Court are expected to strengthen civic education and constitutional literacy among school students across Tamil Nadu.

Sanjeev Sirohi, Advocate,
 s/o Col (Retd) BPS Sirohi, A - 82, Defence Enclave,
 Sardhana Road, Kankerkhera, Meerut – 250001, Uttar Pradesh.