Madhva, Mohammad, Kabīr, Nānak, Gāndhi, be taught; (3) that in the second year some selections of a universalist character from the scriptures of the world be studied; (4) that in the third year, the central problems of the philosophy of religion be considered (Mahadevan, 1971: 283). The next commission to address this issue was what came to be called the Kothari Commission, an education commission (1964–1966) which was chaired by Dr. K.S. Kothari. The Kothari Commission made an important distinction between 'religious education' and 'education about religion', and explained the distinction as follows: The former is largely concerned with the teaching of the tenets and practices of a particular religion, generally in the form in which the religious group envisages them, whereas the latter is a study ofbe provided in any educational institution wholly maintained out of State funds' (Sen, 2010: 93). The case for introducing the study... 25 In pronouncing its judgement, the Court made a distinction between religious instruction and the study of religions as follows: 'To provide for academic study of life and teaching or the philosophy and culture of any great saint of India in relation to or the impact on Indian and world civilizations cannot be considered as making provision for religious instruction' (Sen, 2010: 91). In other words, the Court was outlining a distinction between the confessional and the non -confessional or academic study of religion. The situation got clarified further in the Aruna Roy v. Union of India case of 2002. The National Council of Educational Research and