The Madras High Court has overturned a punishment imposed on Abdul Khadar Ibrahim, a Muslim police constable, for maintaining a beard in accordance with his religious beliefs. The single-judge bench, led by Justice L Victoria Gowri, ruled that the Madras Police Gazette of 1957 permits Muslim officers to keep a trimmed and tidy beard.
Justice Gowri said that while discipline in the police force is important, it should not infringe on the religious practices of its members. The court highlighted that maintaining discipline should not result in penalizing minority community members for their religious observances.
“Upkeeping discipline in the department does not permit the respondents to initiate punishment on employees belonging to the minority communities, particularly Muslims, for maintaining a beard which they do throughout their lives,” the court stated.
Abdul Khadar Ibrahim, appointed as a Grade II police constable in March 2009 and later promoted in 2019, faced disciplinary action regarding his beard following his Haj pilgrimage in 2018. Ibrahim, who had taken leave for the pilgrimage, needed an extension due to a leg infection. Despite providing a medical certificate, he faced scrutiny over his beard when he requested an extension from the Assistant Commissioner.
On October 24, 2019, Ibrahim was asked to explain his beard and subsequently faced disciplinary action for not returning to duty on time and for his beard. On March 23, 2021, the Deputy Commissioner of Police issued a punishment order, halting Ibrahim’s salary increment for three years with cumulative effect. This was later modified to a two-year stoppage of increment without cumulative effect following Ibrahim’s appeal.
Dissatisfied with this decision, Ibrahim filed a writ petition under Article 226 of the Constitution, seeking to have the punishment quashed. He argued that his beard was a religious requirement commanded by the Prophet Mohammad (PBUH) and that the 1957 Madras Police Gazette allowed Muslim officers to maintain a trimmed beard. His counsel also contended that the authorities did not consider Ibrahim’s medical condition properly.
Justice Gowri referred to the 1957 Gazette and noted that Muslim officers were entitled to maintain trim and tidy beards while on duty. The court criticized the disciplinary action as excessively harsh and disproportionate, leading to the quashing of the punishment order. The matter has been remanded to the Commissioner of Police, Madurai City, for further consideration.
