Ramesh Baghel vs State of Chhattisgarh (2025) - Case Analysis

Why in the Spotlight? - Ramesh Baghel vs State of Chhattisgarh (2025)

The case of Ramesh Baghel vs State of Chhattisgarh (2025) is a landmark judgment considering constitutional issues of equality, secularism and personal liberty. The case highlighted religious discrimination, legality of private land burials and the conflict between individual rights and public order. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgments.

Introduction of Ramesh Baghel vs State of Chhattisgarh (2025)

The case of Ramesh Baghel vs State of Chhattisgarh (2025) centred around a plea filed by the Petitioner, a Christian tribal from Chhindwada and sought permission to bury his deceased father either on private agricultural land or in the community burial ground traditionally used by the Mahra caste. The Gram Panchayat opposed the request which led to legal questions on constitutional rights, secularism and administrative regulations regarding burial grounds.

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Historical Context and Facts of Ramesh Baghel vs State of Chhattisgarh (2025)

The case at hand revolves around the plea filed by the Petitioner Ramesh Baghel to bury his deceased father in Chhindwada village either on private agricultural land or in the community burial ground which was opposed by the Gram Panchayat and villagers. The following are the brief facts of the Ramesh Baghel vs State of Chhattisgarh -

Background of the Petitioner: The Petitioner Ramesh Baghel is a Christian tribal from the village of Chhindwada who sought permission to bury his deceased father, who was a pastor by vocation.

Request for Burial in Native Village: The Petitioner Ramesh Baghel requested that the burial be allowed either in the existing burial ground traditionally used by the Mahra caste or on his private agricultural land in Chhindwada. He highlighted that his ancestors including his grandfather and aunt had previously been buried in the same village burial ground.

Opposition from Gram Panchayat and Villagers: The Gram Panchayat along with the local villagers objected to the request and asserted that the burial ground was exclusively reserved for Hindu tribal members. They argued that a designated Christian burial ground already existed in Karkapal village which was approximately 20–25 kilometers away from Chhindwada.

Ramesh Baghel Plea to the Chhattisgarh High Court: The Petitioner Ramesh Baghel approached the Chhattisgarh High Court. He argued that the burial should occur in the native village as per their tribal customs and family tradition. As an alternative, he requested permission to use his private agricultural land for the burial.

Justification by State and Gram Panchayat: The State government and the Gram Panchayat contended that burials must strictly occur in designated areas as directed by the Chhattisgarh Panchayat Rules. They maintained that allowing burials in unauthorized areas, even private land could disrupt public harmony and set a problematic precedent.

Issue addressed in Ramesh Baghel vs State of Chhattisgarh (2025)

The following issues were addressed in Ramesh Baghel vs State of Chhattisgarh -

Violation of Fundamental Rights (Article 14, Article 15 and Article 21): The main question which was addressed in Ramesh Baghel vs State of Chhattisgarh was whether the refusal by the Gram Panchayat to permit the burial of the Appellant’s father within Chhindwada village violated the constitutional principles of Article 14, Article 15 and Article 21 of Indian Constitution?

Secularism and Fraternity: Whether denying burial rights to a Christian family highlighted a failure of the State to uphold the constitutional mandate of secularism and fraternity?

Legality of Burials on Private Land: In Ramesh Baghel vs State of Chhattisgarh the Supreme Court also examined whether burials be allowed on private agricultural land in the absence of designated burial grounds and what are the legal and administrative implications of granting burial rights on private property, particularly concerning public health and order?

Legal Provisions involved in Ramesh Baghel vs State of Chhattisgarh (2025)

Article 14, Article 15 and Article 21 of Indian Constitution played a significant role in the case of Ramesh Baghel vs State of Chhattisgarh. The following are the analysis of these provisions -

Article 14 of the Constitution of India: Equality before Law

Article 14 deals with equality before law. It states that the State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India.

Article 15 of Constitution of India: Prohibition of Discrimination

1. It prohibits the State from discriminating against any citizen on the grounds of religion, race, caste, sex or place of birth. The clause bolsters the principle of equality before the law.
2. It highlights the principle of equality and ensures that no citizen is subject to discrimination in public spaces and have -

1. Access to shops, restaurants, public entertainment
2. essential amenities like wells, bathing ghats and roads

1. The provision enables the State to make special provisions for the protection and advancement of women and children and recognize their vulnerable status in society.
2. The State can make special provisions for the advancement of socially and educationally backward classes i.e., Scheduled Castes (SCs) and Scheduled Tribes (STs). Article 15 Clause (3) & Clause (4) are exceptions to Clause (1) and (2).
3. This clause was inserted by the 93rd Amendment Act, 2005. It allows the State to implement special provisions for the admission of socially and educationally backward classes, SCs and STs to educational institutions including private institutions.
4. It enables the State to make provisions for the advancement of economically weaker sections of citizens. The clause was inserted by the 103rd Amendment Act, 2019. These provisions include reservations for such sections in educational institutions with a limit of 10% of the total seats.

Article 21 of Constitution of India: Protection of Life and Personal Liberty

Article 21 deals with protection of life and personal liberty. It states that no person shall be deprived of his life or personal liberty except according to procedure established by law.

Judgment and Impact of Ramesh Baghel vs State of Chhattisgarh (2025)

On 27th January, 2025, the 2-Judge Bench of the Supreme Court comprising Justice B.V Nagarathna and Justice Satish Chandra Sharma delivered a split verdict in Ramesh Baghel vs State of Chhattisgarh. The plea was filed by a Christian man from Chhattisgarh who sought permission to bury his deceased father either on private agricultural land in Chhindwada or in the village burial ground traditionally used by the Mahra tribal community. The case examined constitutional questions involving equality, secularism and administrative regulations with the judges adopting divergent views on balancing individual rights and public order.

Justice B.V. Nagarathna ruled in favor of the Appellant Ramesh Baghel and allowed him to bury his father on private agricultural land in Chhindwada. In Ramesh Baghel vs State of Chhattisgarh she noted that denying this request infringed constitutional principles including secularism, equality under Article 14 and prohibition of discrimination under Article 15. She criticised the Gram Panchayat for its failure to provide a burial ground for Christians and described this inaction as a discriminatory governance failure.

Justice B.V. Nagarathna highlighted that secularism and fraternity are important constitutional principles and noted that resolving such disputes at the local level with mutual respect would foster harmony. She also emphasised that no community should face exclusion in accessing basic facilities such as burial grounds. As part of her judgment in Ramesh Baghel vs State of Chhattisgarh, she issued directions and permitted the burial on private agricultural land, directed police protection for a peaceful burial and instructed authorities to demarcate and allocate burial grounds for Christians across the state within two months.

On the contrary, Justice Satish Chandra Sharma upheld the Chhattisgarh Panchayat Rules which require burials to take place only in designated grounds. He supported the decision of the Chhattisgarh High Court and directed that the burial occur at the Christian burial ground in Karkapal village, approximately 20 to 25 kilometers from Chhindwada. He dismissed the request of the Appellant to bury his father on private land and reasoned that permitting such burials could set a dangerous precedent, spark disputes and undermine public order and hygiene. Justice Sharma in Ramesh Baghel vs State of Chhattisgarh highlighted that adherence to the designated burial grounds was important for maintaining community harmony and administrative efficiency. He ordered the state to provide logistical support and police protection to ensure a peaceful burial at Karkapal.

Despite their opposing views, the 2-Judge Bench agreed not to refer the matter to a larger bench due to the prolonged delay and the need for a prompt resolution. Thus, the Bench invoked Article 142 of Indian Constitution and issued a consensual order directing the burial to occur at the designated Christian burial ground in Karkapal with state-provided logistical and police support.

Conclusion

In Ramesh Baghel vs State of Chhattisgarh (2025) the split verdict of the Supreme Court highlighted a complex balance between individual rights and public order. Justice B.V. Nagarathna underlined constitutional principles of equality and secularism by permitting burials on private land whereas Justice Satish Chandra Sharma upheld administrative rules favoring designated burial grounds. Thus, the burial was ordered at Karkapal’s Christian burial site under police protection as per a consensual directive under Article 142 of the Constitution.