the contention that the suggestion of the NFSCE went against article 28 of the Indian constitution. Speaking for the court, M.B. Shah, J did so on three grounds. First, he alluded to the government committee reports which advocated value based education, including the S.B. Chavan committee which stated that religion is a 'most misused and misunderstood concept' and that 'the basics of all religions, the values therein, and also a comparative study of the philosophy of all religions should begin at the middle stage in schools and continue up to the university level' (Sen, 2010: 90–91). Next, he argued that the suggestion was consistent with article 51 -A of the constitution which declares it as one of the duties of every citizen to 'promote harmony and the spiritshall be no sectarian indoctrination in State institutions. But history of religion and of religious institutions, comparative religion, philosophy of religion can all be studied even in institutions maintained wholly out of State funds (Sen, 2010: 93). A third Indian feature is provided by the invocation of the word dharma. This point comes out clearly in the concurring judgment of, Dharmadhikari, J in Aruna Roy v. Union of India. His position is summarized by Ronojoy Sen as follows: 1 The distinction was already drawn by Dr. B.R. Ambedkar, who had studied in the U.K. and U.S.A. during the Constituent Assembly debates. He explained while discussing what was to become article 28: 'It is therefore not proper to say that by this article we have altogether barred religious education.