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Dated : 25 June 2015

To,
Shri Raj Nath Singh ji
Honble Union Minister of Home
Ministry of Home Affairs
North Block, Central Secretariat, New Delhi
Sub: REPRESENTATION TO ISSUE AN ORDER TO ALL STATE GOVERNMENTS & UTs AND
HOME DEPARTMENT FOR SAFE MOVEMENT OF JAIN SAINTS AND NON-FILING
OF FIR / NOT TAKING COGNIZANCE ON THE COMPLAINTS MADE AGAINST
DIGAMBER SAINTS IN ALL STATES & UTs OF INDIA
Respected Sir,
With due respect it is submitted that VISHWA JAIN SANGATHAN is actively
engaged in propagating the cause of Jain Religion at different forums. Jainism is an ancient and
independent religion of India with its own philosophy, worships & rituals, social customs and
manners. Jain community had been declared religious minority nationally on dated 27 January
2014 U/s 2C of National Commission for Minorities Act, 1992 at par five other religious minorities
of India.

VISHWA JAIN SANGATHAN is regd. under Societies Registration Act bearing

Registration No. S-51707 and is also registered with Income Tax Department bearing PAN No.
AAAAV3062C and we are doing effective works to promote Jainism, Ahimsa & Vegetarianism
internationally and our organization has played active role to get declaration Jains as a national
minority status during the year 2006 to 2014 from then Govt. of India after a long battle even to
the extent of hunger strike and works done by us have been appreciated by the whole Jain
community as a whole.

Vishwa Jain Sangathan has taken a serious view of the fact that several attempts
have been made recently to kill Jain Saints in road accidents and Goa Court has issued an order
to file FIR against Digamber Jain Saint due to attend a religious function in Margaon, Goa. There
is a feeling that the rights of Jains have been denied what is obviously due to them because they
have not taken the turbulent path of agitation. The Jains are a peaceful community but
appropriate representation should not be withheld from them because of their principled
adherence to peace.

It is also inform you that after getting national minority status, Jains & its religion
have now certain privileges according to the National Commission for Minorities Act & its rules
thereunder specifically which include to protect Jain Saints from any type of criticism or remarks
against them verbally or written or to safe guard them in the public during their procession.

In this connection, Vishwa Jain Sangathan by this representation having details of

nudity as religious practice in different religions since ancient time, definition of person, Saint &
religion and judgements for religious rights etc. at points no. 1 to 51 and prayer at point no. 52
seeks protection of the fundamental constitutional rights under chapter III of the Constitution of
India, guaranteed for the Jains and their holy Saints with the necessity of adequate safety of Jain
Saints during movement in all states of India for your kind information and immediate action in
the interest of Jains and their holy Saints as a whole;
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MOST RESPECTFULLY SHOWETH;

1.
That applicant has a genuine and bonafide interest in the issues which are raised in the
present representation in the interest of Jains and their Saints as a whole.

2.
That Jainism is an independent and most ancient religion of India. Jainism is revealed in
every cyclic period of the universe, and this constitutes the pre-historic time of Jainism.
3. That in the matter Criminal Misc. Application 395 of 2015, on dated 11 May 2015 the court
of Judicial Magistrate at Margao, Goa has directed to the Margao Police to file FIR U/s 294 of
I.P.C. against Digamber Jain Saint to attend a religious function in Margaon, Goa and further
ordered to conduct inquiry as to the other offences which is not acceptable by the Jain
community as a whole of all over the world.

We got shocked & surprised to note the contents of a complaint made by one Shri Atish P.
Mandrekar, Goa at Margao police station, Gao against our holy Jain Saint and Jain community
and we are extremely against such type of complaint made by any person to any authority
nationally and before criticizing or putting our averments against such type of complaint we
would like to mention about Jain religion in a very short & precise manner which will conclude
that such type of complaint are biased and not maintainable as per law.

SAVE JAIN MONKS, SAVE INDIA, SAVE JAINISM

4. KILLING OF JAIN MONKS IN ROAD ACCIDENTS :That it is sad that Jain monks are hit and many times killed on highway by trucks or other
vehicles while walking from one village to other village. A total of 250 Jain monks have died in
the last five years. There was a feeling that there could be some conspiracy behind these
accidents.
Jain monks do not stay at any particular place for a period beyond the prescribed period
under Jainism. They are supposed to move from one place or town to another only by foot. They
are not supposed to use any vehicle. They renounce all worldly possessions and comforts when
they become monks. In the light of this, it is very desirable that they get safe road passage while
in transit.
Jain community has suffered huge loss by losing some of the finest monks due to
accidents. We are law abiding citizens and will always be but its so unfortunate to know that
there is no respect for laws and every other day JAIN MONKS ARE TARGETED we lost our monks
not due to walking on highways but due to some anonymous groups playing a VITAL role passing
a wrong message to every other community why this cant be stopped? Killing JAIN MONKS
BRUTALLY? Why Government cannot take any measures to safeguard our JAIN MONKS.
We would like you to draw your attention towards this activities which has no end and
eventually loss of Jainism due to some bad activist in India.

5. That Jains worship good qualities of a person and only the person. Namokar-Mahamantra
is a prayer of virtues. We Jains worship Arihanta, Siddha, Acharya, Upadhyaya and Muni by
reciting Namokar-Mahamantra. They are known as Pancha Paramesthi. Actually NamokarMahamantra is a reverence-mantra. So, this reverence (deep respect) is impersonal. It is focused
on their virtues (good qualities).
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Goa Court has issued an order to file FIR against Jain Muni who is our fifth parameshthi which is
not acceptable by the Jain community as a whole.

6. That it is also relevant to mention that Jain religion itself promote non-violence and peace
principles which have been followed by the leaders of pre and post-independence era which
have contributed in the peace of the nation and as a matter of the fact that nudity mentioned in
the complaint by the said Shri Atish P. Mandrekar is not an obscene and moreover it is a form
which have been taken by a person that i.e. Jain saint after getting proper sanskars and oaths
ceremony from the Jain Aacharya during and the time of Muni deeksha which can not be
evaluated in the terms of the obscenity and it is the eye views of a person who sees that form of
nudity in what manner and it seem a person who has lodged complaint against our Jain saint &
community has no preliminary knowledge about Jains and their religion which required to
present our principles and the following made by the our Jain saints during a day.

7. That Jain Saints travel from one place to another, whatever the distance, they always walk
barefoot. They do not use any vehicle, such as a bullock cart, car, boat, ship or plane etc. for
traveling. Whether the weather is cold or hot; whether the road is stony or thorny; whether it is
the burning sand of a desert or a burning road, they do not wear any footwear at any time,
moving about on bare feet all their life. The reason for not wearing shoes is so that they can
avoid crushing the bugs or insects on the ground. While going places, they preach the religion
(Dharma), and provide proper spiritual guidance to people.

They also do not stay more than a few days in any one place except during Chaturmas and
the rainy season, which is about four months in duration. The ascetics generally do not go out at
night.

8.
That it is but natural that simply by seeing simple natural, child like innocent, naked, Jain
saints people will have conflicting doubt and logical or illogical thoughts, to satisfy those
thoughts and doubts. I am presenting below certain true facts taking moral, spiritual angle in
view. Nakedness being natural and original form of every soul, every one whether he is human
or super human, bird or animal takes birth naked and at the time of his death goes naked living
all the worldly unnatural possessions, but after taking birth to protect himself from heat, Cold
etc. and to hide his evil thought he puts on clothes.
Digamber is only symbolic other-wise one does not become Digamber only by being naked
just as cow, buffalo, birds, mad and persons living in hell etc. all of them are also naked but not
Digamber. When one is very soft and calm in nature by heart and thoughts as well as in behavior
towards others then it is called Digamber, its other name is Nirgranth. Nirgranth means one who
has no room or link for wrath, Pride, wickedness, greed, sexual thoughts, greed sexual thoughts,
bad customs etc. in his inner self and cloths, wealth, wife, Son, money and other things of
comfort for his body worldly attachments.

9. That the discovery of the Indus Civilization seem to have thrown a new light on the antiquity
of Jainism. The evidence suggests that Jainism was known among the people of the Indus Valley
around 3500-4000 B.C. Some nude figures, considered to be of Lord Rishabha, on the seals
have been discovered at Mohenjodaro and Harrappa. The people of the Indus Valley not only
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practiced Yoga but worshipped the images of nude Yogis. There are nude figures in Kayotsarga
posture of standing are peculiarly Jain.
T.N. Ramchandran who was Central Chief Director of Archeological Department of that time,
has examined it cautiously. In his thesis book "Harappa and Jainism" (at page 4) has proved that
the idol is of Tirthankara Rishabhdev and written that:-

"The idol carved in 'Kayotsarga' Mudra in Harappa is fully a Jain idol. On its face the simplicity
or grace appears from distance."

10. That 24th Jain Tirthankar Mahaveer was the senior contemporary of Gautama Buddha,the
founder of Buddhism. in Majjhima Nikaya, Buddha tells "Thus far, SariPutta, did I go in my
penance? I went without clothes. I licked my food from my hands. I took no food that was
brought or meant especially for me. I accepted no invitation to a meal."
Ref.: Pruthi, R.K. (2004). Buddhism and Indian Civilization. Discovery Publishing House. pp.
197203. ISBN 978-81-71418664. Retrieved April 1, 2015.

11.
That In Buddhist books Lord Mahavir is always described as nigantha Nataputta
(Nirgrantha Jnatrputra), i.e., the naked ascetic of the Jntr clan.
There are ample references in Buddhist books to the Jain naked ascetics, to the worship of
Arhats in Jain chaityas or temples and to the chaturyma dharma (i.e. fourfold religion) of 23rd
Tirthankar Parsvanath.

12.
That Chinese traveler Hisun Tsiang, who visited the country of Pundravardhana (now
Bengal state of India) in the second quarter of the seventh century, records that The naked
Nirgranthas (Jain Saints) are the most numerous.
(Ref.: Page No. 60, Vol. XX of Epigraphia Indica, publishes by Archaeological Survey of
India, 1929-30)
13. That the Archaeological Survey of India and State Archaeological Department of different
States had discovered various naked ancient Jaina idols with inscriptions of during 4th Cen. B.C.
to 16th Cen. AD from the different parts of India including Goa which have been kept & displayed
in different Govt. Museums.

14. That when the Alexander invaded India he came across a host of nude Jain saints in Taxila
whom the Greek writers call Gymnosophists. The Greek word connotes the nude philosopher.
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The mystic group of Israel, called the Essenes, was much influenced by these Gymnosophists,
who were preaching their message of Ahimsa, the central truth in Jainism to the people of
Alexandra in Egypt. Historical records tell us that the Greeks were much influenced by Jain
thoughts. Alexander had taken one Jain saint, Calanes with him to his country.
The gymnosophists that the Greeks encountered in 3rd Century B.C. at town of Taxila in
Ancient India, which was an ancient center of Vedic, Jain & Buddhist learning. The naked saints,
whom Alexander met, are sometimes considered to be Digambara Jain monks, who have
continued to practice nudity. References as follows :1. {John Williams (1829). The Life and Actions of Alexander the Great. John Murray. p. 314}
2. {The Greeks in India: a survey in philosophical understanding. Demetrios Theodossios
Vassiliades. 2000. pp. 46, 49.}
3. {The Greeks in India:a survey in philosophical understanding, page 49}
15. That Gymnosophists (Greek word i.e. "naked philosophers" or "naked sophists") is the
name given by the Greeks to certain ancient Indian philosophers who pursued asceticism to the
point of regarding food and clothing as detrimental to purity of thought (sadhus or yogis) and
also even naked priests from Ethiopia.
Ref.: {Liddell, Henry George; Scott, Robert; A GreekEnglish Lexicon at the Perseus Project}
{Quests of the Dragon and Bird Clan By Paul Kekai Manansala. 2006. p. 282.}
16. That one such noted gymnosophist was Calanus. Before immolation, he is said to have
prophesied the death of Alexander at Babylon.
Ref.: {A history of Hindu civilisation during British rule: Volume 1, 1894, page 72, Self-immolation
is ancient practice of India called Maha-nirvana.}
{History of Philosophy By Silvano Borruso. 2007. p. 50.}
17.
That another noted gymnosophist by Greeks was Dandamis, a Brahmin and the guru of
Calanus. Alexander later learned Indian philosophy from him.
Ref.: [The Legends of Alexander the Great By Richard Stoneman. 2012. pp. 4344.]
18.

That the naked priests from Ethiopia were also called gymnosophist by Greeks.
Ref.: {The life of Apollonius of Tyana: Translated from the greek of Philostratus By Flavius
Philostratus, Edward Berwick. 1809. p. 322.}
{A Postcolonial Commentary on the New Testament Writings by Fernando F. Segovia,
R. S. Sugirtharajah - 2009 - page 149}

19. Nakedness of Digamber Jain Saints :i) That Nakedness is a virtue of not only Jainism but in almost every religion of the world.
Nakedness is the glowing example of socialism and APRIGRAH (Possession less) of a very high
order. Every Digambara Saint is required to follow the 28 vows (vrats) compulsory. Naked Jain
saints present an example of socialism and aprigrahvad denouncing the love and possession of
worldly wealth and essentials of very high order by discarding gold, silver, money other valuables
and even this necessary to protect his body.
Not to cover the body with cloths, leather, bark leaves or any other thing and to live
naked without any possession and fashion or adornment is known in the word as a worship able
virtue by the name of Nirgranth or Digamber. Digamber means whose clothe all are all direction
(East, west, north, south, earth & sky) only.
Sharman (Nirgranth Saints) are expert par excellence in the knowledge of Soul. Muni are
naked having only two possessions, a Morpichhi and a Kamandal (water gourd) in their hands.

ii) Jagat guru Shankracharya has written in 'Vive Chudamani' that saint who keeps only
all the directions as his clothes are, he lives Digamber, he in his exalted state by becoming
absolutely free from worries is capable to enjoy the pleasure of knowing the soul.

iii) It is written in Ram Krishan Katha Amrit that Ram Krishan attained the state of highest
Virtue. On awaking from sleep his follower say it is day break. Ram Krishan is naked like a child
and there is not a single thread on his body Swamiji said to his follower Ashwani Kumar Dutt.
"When I forget all physical attachments then clothes are also off."

iv) The feature of naked sadhus is still fairly common, even in modern India. Overseas
visitors seldom see them because they seldom live or visit the tourist fleshpots and city
terminals. When Allen Ginsberg, the American poet, visited India some years back, he expressed
in letters which were printed in City Lights his sad disappointment at not seeing even one naked
sadhu. This could be surprising because in Banaras, which he visited, it is doubtful if this great
city of Shiva has ever been without naked sadhus and in considerable numbers. Banaras is still
the one city in India where you can walk about naked and yet remain unnoticed.
v) All Upanishadic and Gita teachings lead to the one simple but inescapable truth that we
are not bodies but immortal souls. So what does an immortal want to hide and should they try
to look like worldly men? The word Digamber is taken from the Sanskrit Dig-ambara. Its literal
meaning is wearing the sky or sky-clothed. Though often used as a synonym for naked, it has a
much deeper meaning.
A householder is separated from his environment by his clothes, and when he removes
his clothes he is separated from his environment by his skin. He fails to understand or realize the
oneness of all nature and life. This should not be so with the sadhu and when he is digamber he
is one and absolute with everything.
Ref.: [The Naked Saints of India, written by Dadaji, was originally published in the now defunct
Indian magazine Values, edited by the late John Spiers.]

20.
That the antiquities of Mathura are of great importance from Jain point of view, since
they brought to light in existence of a famous Jain establishment at Kankali Tila from the second
century B. C. This site has provided a veritable information of nude Jain sculptures most of which
are now deposited in the Mathura and Lucknow Museums.

21.

That the observations of the eminent archaeologist Ramprasad Chanda are valuable :

The pose of the image (standing Rishabha in Kayotsarga form from Mathura reproduced
in fig 12) closely resembles the pose of the standing deities on the Indus seals. Among the
Egyptian sculptures of the time of the early dynasties (III - VI) there are standing statuettes with
arm hanging on two sides ... But though these Egyptian statues and the archaic Greek Kouri show
nearly the same pose, the lack the feeling of abandonment that characterizes the standing
figures of the Indus seals three to five (plate 11 F. G. II) with a bull in the foreground may be the
prototype of Rishabha.
Ref.: (Modern Review, August 1932 Sindh Five Thousand years Agoplate 11 fig.-d. and p.
Page 159 ).

22. That Relics found from Harrapan excavations like seals depicting 'Kayotsarga' posture, idols
in Padmasana and a nude bust of red limestone give insight about the antiquity of the Digambara
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tradition.
Ref.: Possehl, Gregory L. (2002). (17) The Indus Civilization: A Contemporary Perspective.
Rowman Altamira. p. 111. ISBN 9780759101722. Retrieved 25 April 2015.

23.

NUDITY IN MAJOR RELIGIONS OR THE WORLD:-

i) That The Adamites, an early Christian sect, practiced "HOLY NUDISM", engaging in
common worship in the nude. During the Middle Ages, the doctrines of this obscure sect were
revived: in the Netherlands by the Brethren of the Free Spirit and the Taborites in Bohemia, and,
in a grosser form, by the Beghards in Germany. Everywhere, they met with firm opposition from
the mainstream churches. Ref. {Adamites, Catholic Encyclopedia}
ii) That in the Old Testament both Isaiah in Isaiah 20:2-3 and King Saul in 1 Samuel 19:2324 are described as preaching in the nude.
iii) That Christian naturism is the practice of naturism or nudism by Christians. This form
of naturism is not to be confused with what Durkheim termed "naturism" as an explanation for
the origin of religion. Ref.: Bois 1916.
iv)
That here are other references to nudity in the Bible, such as Mark 14:51-52 "A
young man, wearing nothing but a linen garment, was following Jesus. When they seized him,
he fled naked, leaving his garment behind."
v) That the first recorded liturgy of baptism, written down by Saint Hippolytus of Rome
in his Apostolic Tradition, required men, women and children to remove all clothing, including
all foreign objects such as jewellery and hair fastenings. Ref.: Hippolytus 2013, p. 33.
vi) That Early Christian art included depictions of nudity in baptism. When artistic
endeavors revived following the Renaissance, the Catholic Church was a major sponsor of art
bearing a religious theme, many of which included subjects in various states of dress and
including full nudity. Pl see following picture ;
Representation of baptism in early Christian art

Baptism of Clovis I (496)

vii) That Sects have arisen within Christianity from time to time that have viewed nudity
in a more positive light. For example, to the Adamites and the Doukhobor sect social nudity was
an integral part of their practices.
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That today, Christian naturists maintain that social nudity is a normal part of Christianity
and is acceptable. De Clercq has argued that the significance of the human need for clothing by
far exceeds its theological meaning. Ref.: De Clercq 2011.
viii) That in year 1981, Pope John Paul II expressed the Catholic Church's attitude to the
exposure of the human body in Love and Responsibility: "The human body can remain nude and
uncovered and preserve intact its splendour and its beauty... Nakedness as such is not to be
equated with physical shamelessness... Immodesty is present only when nakedness plays a
negative role with regard to the value of the person... The human body is not in itself shameful...
Shamelessness (just like shame and modesty) is a function of the interior of a person." Ref.:
Wojtyla 2013

ix) That the physical exposure is a functional part testing endurance, e.g., to undergo
scarification, as among various Australian Aboriginal and Sepik River tribes in New Guinea.
x) That in India;
a) Digambara ascetic monks reject any form of clothing and live naked, or 'sky clad'.
Digambara is one of the two main sects of Jainism. Ref.: "Religion & Ethics - Jain sects". BBC.
Retrieved 2012-08-01
b) the ancient Shramanas, which included the Digamber sect of Jain monks, who also
remain unclothed. They have been identified also with gymnosophists by researchers.
Ref.: {Jacquetta Hopkins Hawkes, the Atlas of Early Man, St. Martin's Press, 1993.}
{Professor A.L. Basham, My Guruji, Sachindra Kumar Maity, 1997.}
{Journal of the Royal Asiatic Society, Volume 6 by the Royal Asiatic Society of Great Britain
and Ireland. 1841. p. 384.}
xi) That there is a tradition in some neopagan Wiccan covens of ritual nudity, called going
skyclad.
xii) That in Judaism, nudity is an aspect of body modesty which is regarded as very
important in most social and familial situations.
xiii) That in ancient South Asian cultures, there was a tradition of extreme asceticism
(obviously minoritarian) that included full nudity. This tradition continued from the
gymnosophists (philosophers in antiquity) to certain holy men (who may however cover
themselves with ashes) in present day Hindu devotion.
xiv)
That among the Hindu religious sects, only the sadhus (monks) of the Nga sect can
be seen nude. {Ref.: Crooke 1919}. Nudist sages can be seen in Pashupatinath, Nepal.
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Hindu Naga Saints :The Naga sadhus (naked monks) who belong to the Dashanami Sampradaya,
founded by Sankaracharya, are often called Indian gymnosophists. They are mostly worshipers
of Shiva[10] and carry Trishula, swords and even other weapons. They were known for taking
arms for defending faith. They have the right to lead the procession at Kumbh Melas. Ref.:
{The Penguin book of Indian journeys by Dom Moraes. Viking. 2001. p. 97.}
{Autobiography of a Sadhu: A Journey Into Mystic India By Rampuri. 2010. p. 102.}
{The Spectator, Volume 256, 1986 - pp 16...the naked ash-smeared Naga sadhus whom
Alexander's men called the gymnosophists are the most prized.}

xv) New religious movements :a) Neopaganism :- In many modern neopagan religious movements, such as
Wicca, social and ritual nudity is (relatively) commonplace. In Wicca, the term
skyclad refers to ritual nudity instead of social nudity.
Ref.: Zimmermann, Denise and Katherine Gleason (2006).
The Complete Idiot's Guide to Wicca and Witchcraft. New York: Penguin.
p. 77. ISBN 1592575331. Retrieved 26 December 2014.
b) In Raelism, nudity is not problematic.
24. History of Nudity : a) Ancient Egypt :That the Hebrew Bible records: "So shall the king of the Assyrians lead away the prisoners
of Egypt, and the captivity of Ethiopia, young and old, naked and barefoot, with their buttocks
uncovered to the shame of Egypt". Ref.: Isaiah 20:4
Women entertainers perform at a celebration in Ancient Egypt; the dancers are naked
and the musician wears a typical pleated garment as well as the cone of perfumed fat on top of
her wig that melts slowly to emit its precious odors; both groups wear extensive jewelry, wigs,
and cosmetics; neither wear shoes. Ref.: Thebes tomb c. 1400 B.C. ;

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b) Sport activities performed naked throughout history of mankind ;

c). Ancient Greece:That Polybius asserts that Celts typically fought naked, "The appearance of
these naked warriors was a terrifying spectacle, for they were all men of splendid physique and
in the prime of life." Ref.: Polybius, Histories II.28
While Greek sculpture often showed males completely nude, a new concept for
females, "Venus Pudica" (or partially nude) appeared: see the Greek "Nike of Samothrace"
d). Ancient Rome:That Ancient Roman attitudes toward male nudity differed from those of the
Greeks, whose ideal of masculine excellence was expressed by the nude male body in art and in
such real-life venues as athletic contests. The toga, by contrast, distinguished the body of the
adult male citizen at Rome. Ref.: Habinek 1997, p. 39.

e) That complete nudity among men and complete or near-complete nudity among
women is still common for Mursi, Surma, Nuba, Karimojong, Kirdi, Dinka and sometimes Massai
people in Africa, as well as Matses, Yanomami, Suruwaha, Xingu, Matis and Galdu people in
South America. Ref.: active naturists: nudity throughout history

f) Ibn Battuta (13041369) judges the character of the people of Mali:

That among their bad qualities are the following. The women servants, slavegirls, and young girls go about in front of everyone naked, without a stitch of clothing on them.
Women go into the sultan's presence naked and without coverings, and his daughters also go
about naked. Ref.: Chughtai.

g) That in 1498, at Trinity Island, Trinidad, Christopher Columbus found the women
entirely naked, whereas the men wore a light girdle called guayaco. At the same epoch, on the
Para Coast of Brazil, the girls were distinguished from the married women by their absolute
nudity. The same absence of costume was observed among the Chaymas of Cuman, Venezuela,
and Du Chaillu noticed the same among the Achiras in Gabon. Ref.: Dr. Jacobus X (pseud.) 1937,
p. 183.
h) That In his book, Cinema Au Naturel (Introduction on page 11), author Mark
Storey states notes "two related terms that we will continually run across are nudist and naturist.
Although the meanings of the two terms are virtually identical, they often have different
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connotations for those who prefer one to the other. In America people who believe that it is
physically, socially, emotionally, and perhaps spiritually healthy to go about fully nude
individually and in groups of mixed sex whever weather permits and others are not offended
generally refer to themselves as "nudists". In Europe such people more often than not refer to
themselves as "naturists."
i) That it is an assessment with which the Head of Delhi University's Department
of Anthropology Prof. Surinder Nath, broadly agrees;
"The origin of nudity in India is very old. It dates back to the Vedic period. The
evidence is right there for everyone to see - there are the sculptures in Khajurao temple, the
Konark temple and many more. We go back a long time. It starts from the Ashoka period where
everything is depicted. In south India, there are still semi-clad Vishkanyas who promote nudity.
Ref.: http://www.hindustantimes.com/nm3/sadhus-went-naked/article1-31109.aspx
j) Indus Valley ; Relics found from Harrapan excavations like seals depicting
'Kayotsarga' posture, idols in Padmasana and a nude bust of red limestone give insight about the
antiquity of the Digambara tradition.
Ref.: Possehl, Gregory L. (2002). (17) The Indus Civilization: A Contemporary Perspective.
Rowman Altamira. p. 111. ISBN 9780759101722. Retrieved 25 April 2015.

25.

Famous scholar Heinrich Zimmer views for Digamber ;

those whose, garment (ambara) is the element that fills the four quarters of space (digdirections). Ref.: Zimmer 1953, p. 210.

26.

That in Hindus ;
i) holy Padam Puran, it has been written that Nirgrantha (Jain saint) was nacked.
ii) Oldest holy RIGVEDA refers naked saints by the word 'VATRASHNA'.
iii) holy 'YAJURVED' says that Bhagwan Mahavira was naked.
iv) In Mahabharat Bhagwan Shri Krishan said to Arjun ;

When Arjun was getting ready for battle one Digamber Muni was coming, seeing him
Krishna said0 Arjun for what you are waiting, get on the chariot and take Gandivo (bow) see,
Nirgranth Muni Raj is in your front, I believe by fighting now you can conquer the earth."

27. That the description of Nirgrantha saints are available in Vishakhapattdhammpadtat story
at chapter 9, part 2 & page 384)

28. World Famous Nude Statue of Bhagwan Bhubali in Shravana Belgola, Karnataka :That the 17-metre-high nude statue of Bhagwan Bhubali that dominates Shravana Belgola
was erected at the end of the tenth century. Set at the top of Vindhya-Giri, this idol is often
referred to as Gommaa or Gommaevara, which are alternate names of Bhubali.
The statue shows this spiritual hero standing in the meditation posture known as
Kyotsarga, with which he is closely associated.

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29. Definition of Saint :i) That in Allahabad High Court in the matter (1918) ILR 40 All 393 of Emperor vs
Maha Ram And Ors. on 25 February, 1918 Bench: G Knox, Walsh}10. Murray in the Oxford
Dictionary, (Volume VII, 1909), interprets the word "profess" thus :--"To affirm or declare one's faith in or an allegiance to; to acknowledge or formally
recognize as an object of faith or belief (a religion, principle, rule of action, God,
Christ, a Saint, etc.)"
ii) That the use of the term "Saint" is not exclusive to Christianity. In many religions,
there are people who have been recognized within their tradition as having fulfilled the highest
aspirations of religious teaching. In English, the term saint is often used to translate this idea
from many world religions.
A saint is a person who is recognized as having an exceptional degree of holiness, or
likeness to God. While the English term "Saint" originated in Christianity, historians of religion
now use the appellation "in a more general way to refer to the state of special holiness that
many religions attribute to certain people, with the Jewish Tzadik, the Islamic Mu'min, the Hindu
rishi or Sikh guru, and the Buddhist arhat or bodhisattva and also being referred to as "Saints".
Ref.: {Lindsay Jones, ed. (2005). Thomson Gale Encyclopedia of Religion (in Tajik).
Sainthood (Second ed.). Macmillan Reference USA. p. 8033.}

iii) That as per Oxford Dictionary, the definition of Saint is a very good or religious
person who is given special respect...., a very good, kind person.

30.

Naturism :-

That according to the XIV Congress of the International Naturist Federation (Agde, France,
1974), naturism is:
A lifestyle in harmony with nature, expressed through social nudity, and characterised
by self-respect of people with different opinions and of the environment. {Ref. : Choin 2002.}

31.

That in 1902, a series of philosophical papers was published in Germany by Dr. Heinrich

Pudor, under the pseudonym Heinrich Scham, who coined the term Nacktkultur.
In 1906 he went on to write a three volume treatise with his new term as its title, which
discussed the benefits of nudity in co-education and advocated participating in sports while
being free of cumbersome clothing.

32. That Richard Ungewitter (Nacktheit, 1906, Nackt, 1908, etc.) proposed that combining
physical fitness, sunlight, and fresh air bathing, and then adding the nudist philosophy,
contributed to mental and psychological fitness, good health, and an improved moral-life view.
{Ref.: Buchy 2005.}

33. That Aurangzeb orders the execution of Sarmad, a Jewish Philosopher who accepted Islam
but stood for freedom of conscience.
14

Sarmad was a well known saint who came to Delhi towards the end of Shah Jahans
reign. Prince Dara Shukoh, the eldest son of Shah Jahan and translator of the Upanishads in
Persian, sought his company and gave him much respect due to a saint and philosopher.
He generally remained in the nude state and had acquired knowledge of the highest nondualism. When summoned to the court and asked to repeat the Kalima, he only went so far as
to declare that there is no God, saying that his realization went no further. He saw the nondifference between the individual soul of every one and the Supreme Soul. The Mullas decreed
that he must be put to death for apostasy.
When the executioner came with his axe to cut off his head, Sarmad welcomed him with
the words I know you, in whatever form you come and embraced death for the sake of his
views and freedom of conscience.

The sketch shows Sarmad in the Emperors court

34. That three hundred years ago during the reign of emperor Shahjehan, Sufi Saint Mohhmad
Ali used to wander naked in his kingdom, his tomb is in the left wing of Jama Masjid at Delhi.
He used to say that God cloths the sinners and allows innocents and pious naked.
Jalani Muslim Saint used to live naked.
The higher saints of Islam called Abduls went about perfectly naked.
Ref.: {"Mysticsm and magic in Turky" by Miss duecy M. gont}

35. Religion:That a religion is an organized collection of beliefs, cultural systems, and world views that
relate humanity to an order of existence. Many religions have narratives, symbols, and sacred
histories that aim to explain the meaning of life, the origin of life, or the Universe. From their
beliefs about the cosmos and human nature, people may derive morality, ethics, religious laws
or a preferred lifestyle.

36. Definition of Religion :i) That there are numerous definitions of religion and only a few are stated here. The
typical dictionary definition of religion refers to a "belief in, or the worship of, a god or
15

gods"{The Chambers Dictionary. Chambers] or the "service and worship of God or the
supernatural". {Merriam-Webster Dictionary} However, writers and scholars have expanded
upon the "belief in god" definitions as insufficient to capture the diversity of religious thought
and experience.

ii) The Merrian Webster Dictionary defined , Religion as an organized system of faith
and worship, a personal set of religious belief and practice, a cause, principle or belief held to
with faith and order.

iii) The Oxford Dictionary defined, Religion the belief in a super human controlling power,
especially in personal God or Gods entitled to obedience and worship. Every individual of India
has a natural entitlement of religious faith and freedom of conscience, a right to adopt or
abandoned any faith of his own choice. In this sense freedom of religion and freedom of
conscience is fundamental right both constitutionally and conventionally.

37.
That being naked in public in Portland is legal if it falls within the guidelines of ORS
163.465 (Public indecency)
http://bikeportland.org/2011/06/17/police-bureau-releases-statement-on-legality-of-nakedbike-ride-55056

38. That in March 2007, a newspaper editor BV Seetharam was arrested under the Sections
153A, 153B, and 295 of the IPC for allegedly promoting religious hatred. He had written articles
criticizing the public nudity of the Digambara Jain monks.
Ref.: {Freedom of expression under attack by Parvathi Menon. The Hindu. March 8, 2007.}

39.

International legislation on the freedom Right Of Religion And Belief :-

That the most important international legislation on the freedom of religion or belief is
Act 18, guaranteed that everyone shall have the right to freedom of thought, conscience &
religion, and this freedom in the United Nations International Covenant on Civil and Political
Rights (CCPR) from, 1966. CCPR Act 18 is built upon Article 18 of the Universal Declaration of
Human Rights (DHR) from 1948.
The General Assembly of united nations adopted without dissenting vote on 10th
December, 1948 the Universal Declaration on Human Rights recognizing fact that the entire
humanity enjoys certain alienable rights which constitute the foundation of freedom, justice and
peace in the world.
The Government of India by its declaration dated 10.4.1979 had accepted Universal
Declaration of Human Rights and the two international covenants.

40.
That the right to freedom of faith is not a conferred right but a natural entitlement of
every human being. In fact law does not assign it but it asserts, protect and insurers its
entitlement. Indian Society has nourished and nurtured almost all the established religion of the
world like Hinduism, Islam, Christianity, Buddhism, Jainism, Sikhism etc. from it is time
immemorial.

16

Article 25 of the Constitution of India incorporates right to practice, profess and

propagation of faith not only this, the Article guarantees the freedom of conscience. Right to
possess adopt abandoned faith is ascribed by a person since his birth. India is a heterogeneous
and pluralist society with multiplicity of faith and cultures. India most fundamental code of
governance. i.e. The constitution of India also asserts, protects and ensures this right to all
individuals irrespective of their religions, under its various provisions especially Article 25.
The Constitution of India also enshrines the freedom of religion and freedom of
conscience as fundamental rights to every of its citizen under Article 25,26,27,28 & 30.
The term religion is not defined in the Indian constitution. However the Supreme
Court has considered this in Comm. HRE Vs. L. T. Swamia AIR 1954 SC282 & S. P. Mittal v Union
of India AIR 1983 SC1 A Religion has its basic in a system of belief or doctrines which are
regarded as those who profess that religion as conducive to their spiritual well being.
Thus the constitution endeavors to protect the persons belief on his religion.

41. That the scope of Article 25 has been repeatedly interpreted by the Apex Court right from
its leading judgment in Sardar Syedna Taher Saifuddin Saheb Vs. The State of Bombay [(1962)
SUPP SCR 496].
The said judgment holds that the protection of Article 25 and 26 extends to rituals and
observances, ceremonies and modes of worship which are intergral parts of religion. Thus,
unless such ceremonies are found to be an integral part of religion, the protection under Article
25 cannot extended.
The learned amicus curiae has relied upon the decision of the Commissioner of Police and
Others Vs. Acharya Jagdishwarandanda Avadhuta and Anr [(2014)12 SCC 770]. In paragraph 9 of
the said decision, the Apex Court observed thus :
"9. The protection guaranteed under Articles 25 and 26 of the Constitution is not confined
to matters of doctrine or belief but extends to acts done in pursuance of religion and,
therefore, contains a guarantee for rituals, observances, ceremonies and modes of
worship which are essential or integral part of religion. What constitutes an integral
or essential part of religion has Shiv 24 pil8.12 to be determined with reference to its
doctrines, practices, tenets, historical background etc. of the given religion.
What is meant by 'an essential part or practices of a religion' is now the matter for
elucidation. Essential part of a religion means the core beliefs upon which a religion
is founded. Essential practice means those practices that are fundamental to follow
a religious belief. It is upon the cornerstone of essential parts or practices the
superstructure of religion is built. Without which, a religion will be no religion. Test to
determine whether a part or practice is essential to the religion is to find out whether
the nature of religion will be changed without that part or practice.
It is such permanent essential parts is what is protected by the Constitution. No body
can say that essential part or practice of one's religion has changed from a particular
date or by an event. Such alterable parts or practices are definitely not the 'core' of
religion where the belief is based and religion is founded upon. It could only be treated
as mere embellishments to the non- essential part or practices."
(emphasis added) Shiv 25 pil8.12 the test laid down by the Apex Court to determine
whether a practice or part thereof is essential to a religion is to find out whether the
nature of the religion will be changed without that part or practice. If the taking away
that part of practice could result in a fundamental change of the character of that
religion, then such part could be treated as an essential or integral part.
17

{In Bombay High Court in the matter PIL 8 of 2012 of Campaign Against Manual ...
Vs. The State Of Maharashtra And Ors on 5 March, 2015 Bench: A.S. Oka}
42. That the Senior Staff Officer of Department of Public and Home Safety, Govt. of Rajasthan
has issued an order dated 3rd Feb 2015 vide no. 3205-37 as per letter dated 20.01.2015 vide no.
203 of the Minister of Home, Govt. of Rajasthan to provide home guards for safety of Jain Saints
during movement in Rajasthan State.

43. That as per Section 294 of the Chapter XIV of the Indian Penal Code for Obscene acts and
songs Whoever, to the annoyance of others
a) does any obscene act in any public place, or
b) sings, recites or utters any obscene song, ballad or words, in or near any public places,
44. That what is obscenity has not been defined either in s. 292 IPC or in any of the statutes
prohibiting and penalizing mailing, importing, exporting, publishing and selling of obscene
matters. The test that has been generally applied in this country was that laid down by Cockburn,
C.J. in Hicklin's case(1) and even after the inauguration of the Constitution and considered in
relation to the fundamental right of freedom of speech and expression this test, it has been held,
should not be discarded.
In Hicklin's case(1) while construing statutes 20 and 21 Victoria, a measure enacted
against Obscene books, Cockburn, C.J. formulated the test in these words:
"I think the test of obscenity is this, whether the tendency of the matter charged as
obscenity is to deprave and corrupt those whose minds are open to such immoral influences,
and into whose hands publication of (1) [1868] L.R. 3 Q.B. 360.
this sort may fail... It is quite certain that it would suggest to the minds of the young of
either sex, or even to persons of more advanced years, thought of most impure and libidinous
character."
This Court has in Udeshi v. State of Maharashtra (1) considered the above test and also
the test laid down in certain other American cases. Hidayatullah, J. as he then was, at the outset
pointed out that it is not easy to lay down a true test because
"art has such varied facets and such individualistic appeals that in the same object the
insensitive sees only obscenity because his attention is arrested, not by the general or artistic
appeal or message which he cannot comprehend, but by what he can see, and the intellectual
sees beauty and art but nothing gross." It was also pointed out in that decision at p. 74,
"None has so far attempted a definition of obscenity because the meaning can be laid
bare without attempting a definition by describing what must be looked for.
It may, however, be said at once that treating with sex and nudity in art and literature
cannot be regarded as evidence of obscenity without something more.
It is not necessary that the angels and saints of Michelangelo should be made to wear
breeches before they can be viewed.
If the rigid test of treating with sex as the minimum ingredient were accepted hardly
any writer of fiction today would escape the fate Lawrence had in his days.
Half the book-shops would close and the other half would deal in nothing but moral
and religious books which Lord Campbell boasted was the effect of his Act."
18

It is, therefore, the duty of the court to consider the obscene matter by taking an overall
view of the entire work and to determine whether the obscene passages are so likely to deprave
and corrupt those whose minds are open to such influences and in whose hands the book is
likely to fail and in doing so one must not overlook the influences of the book on the social
morality of our contemporary society. We can do no better than to refer to this aspect in the
language of Hidayatullah, J. at p. 76:
"An overall view of the obscene matter in the setting of the whole work would, of
course, be necessary, but the obscene matter must be considered by itself and separately to
find out whether it is so gross and its obscenity so decided that it is likely to deprave and
corrupt those whose minds are open to influences of this sort and into whose hands the book
is likely to fall."
{In the Supreme Court of India in the matter Chandrakant Kalyandas Kakodar vs The State Of
Maharashtra And Ors of 1970 AIR 1390, 1970 SCR (2) 80 on 25 August, 1969 Bench: Reddy, P.
Jaganmohan}

45.
That Bombay High Court in the matter Indian Hotel and Restaurants Vs State Of
Maharashtra through in 2006 (3) BomCR 705 Bench: F Rebello, R Dalvi, the honble Court
referred the meaning of Obscenity;
49. We may at this stage note that arguments were advanced as to what is
obscenity. For the purpose of our discussion we may only refer to the judgment of the Apex
Court in Ranjit D. Udeshi v. The State of Maharashtra.
The Apex Court has noted that the test of obscenity as laid down by Cockburn C.J., has
been unformally applied in India. The test is ;
...I think the test of obscenity is this whether the tendency of the matter charged as
obscenity is to deprave and corrupt those whose minds are open to such immoral
influences, and into whose hands a publication of this sort may fall... It is quite certain
46. SOME IMPORTANT JUDGEMENTS FOR RELIGIOUS CONSTITUTIONAL RIGHTS OF EVERY
CITIZEN OF INDIA :1. In the matter ILR (1978) Bombay 1905 (1937, 1938) (DB) :It is not the duty or province of the court to pronounce on the truth of religious
tenets, not to regulate religious rites or ceremonies.
2. In the matter AIR 1978 Ker 68 at S. No. 35 ;
A religious sect or denomination has the undoubted right guaranteed by the
constitution to manage its own affairs
In the matter of AIR 1978 Ker 68 (90) (FB)
The real purpose and intendment of Art. 25 to guarantee especially to the
religious minorities the freedom to profess, practice and propagate their
religion.

3.

In the matter AIR 1921 Bom 338 (355) ;

19

The court will not decide mere questions of religious rites or ceremonies nor
will it pronounce on any religious doctrine unless it is necessary to do so in
order to determine rights to property.

4.

In the matter AIR 1939 Mad 494 (495), AIR 1939 Mad 757 (759) :Doctrine of non-interferance by the state in religious matters is also reflected
in the principle that courts can not take judicial cognizance of disputes as to
religious rites or doctrines and adjudicate upon them except in so far as such
disputes may relate to the right to property or office. It is not the province or
duty of the court to pronounce on the truth of religious tenets nor to
regulate religious rites or ceremonies.

5.

In the matter ILR (1954) Nag 30 = (AIR 1953 Nag 70) :it was observed that the framers of the constitution felt, having regard to the
differences in the two faiths that an express mention might be made of all
faiths exabundanti cautela and to put the matter beyond all controversy, and
that faith is one thing and law is another.

6. In the matter ILR 5 Bom 80 (82) (DB) :It is policy of the state to protect all religions, but to interfere none.

7. In the matter AIR 1954 SC 282 ;

iii) Latham, C.J. of the High court of Australia while dealing with the
provision of S. 116, Australian constitution which inter alia forbids the
commonwealth to prohibit the free exercise of any religion made the
following weighty observations- vide Adelaide company vs the
commonwealth, 67 CLR 116 at p.127 (H):
It is sometimes suggested in discussions on the subject of freedom of
religion that, though the civil government should not interfere with
religious opinions.
8. In the matter Dr M. Ismail Faruqui V. UOI, AIR 1995 SC 605 : (1994) 6 SCC 360
It is clear from the constitutional scheme that it guarantees equality in the
matter of religion to all individuals or groups irrespective of their faith
emphasizing that there is no religion of the state itself. The concept of
secularism is one fact of the right to equality woven as the central golden
thread in the fabric depicting the pattern of the string of our constitution.
9. In the matter ILR (1966) 16 Raj 778 (793) : 1966 Raj LW 566 (DB) (The
Rajasthan Public Trust Act- 1959):does not in any way interfere with the freedom of conscience and the right to
practice, profess freely and propagate the religion of Jains
10. In the matter AIR 1959 Raj 177 (190) (DB) :The guarantee under the Constitution not only protects the freedom of
religious opinion, but it protects also acts done in pursuance of a religious and
20

this is made clear by the use of expression practice of religion in Article 25.
11. In the matter of AIR 1953 Bom 242 (244) (DB) ;
This article protects religious freedom as far as individuals are concerned.
12. In the matter of AIR 1963 SC 1638 (1660), AIR 1972 SC 1586 (1593), AIR 1962
SC 853 (868), AIR 1959 SC 942, AIR 1959 SC 1073, AIR 1959 SC 860 (865) ;
The freedom of religion under this article includes not only freedom to believe
in or profess any religion but also freedom in regard to religious practices, i.e.
acts done in pursuance of religion.
47. That Supreme Court of India in the case of State of H.P. Vs. Pawan Kumar [2005 (4) SCC
350], the honble Court referred the definition of PERSON as a body of human with appropriate
coverings and clothing but not included to religious monks and sages due to their religious
belief as they do not cover their body with clothing ;
"The word "person" has not been defined in the Act. Section 2(xxix) of the Act
says that the words and expressions used herein and not defined but defined in the Code
of Criminal Procedure have the meanings respectively assigned to them in that Code. The
Code of Criminal Procedure, however, does not define the word "person".
Section 2(y) of the Code says that the words and expressions used therein and not
defined but defined in the Indian Penal Code have the meanings respectively assigned to
them in that Code.
Section 11 of the Indian Penal Code says that the word "person" includes any
company or association or body of persons whether incorporated or not. Similar
definition of the word "person" has been given in Section 3(42) of the General Clauses
Act. Therefore, these definitions render no assistance for resolving the controversy in
hand. ....Therefore, the most appropriate meaning of the word "person" appears to be
"the body of a human being as presented to public view usually with its
appropriate coverings and clothing".

For interpreting the provision, rare cases of some religious monks and
sages, who, according to the tenets of their religious belief do not cover their
body with clothings, are not to be taken notice of.
{also mentioned in Appeal (crl.) 1067 of 2005 State Of Rajasthan Vs Daulat Ram on 23
August, 2005 Bench: B.P. Singh, S.H. Kapadia} &
{In Rajasthan High Court at Jaipur Branch in Anoop vs State
(i) S.B.CR. APPEAL NO.1214/2004 (Kedar Bai Vs. State)
(ii) S.B.CR. APPEAL NO.1295/2004 (Anoop Vs. State) D.O.J : January 19,2011
HON'BLE DR.JUSTICE SMT. MEENA V. GOMBER}
48.
That Supreme Court of India in Criminal Appeal No. 860 of 2004 of State of Rajasthan vs
Ratan Lal, the honble Court referred the definition of PERSON as a body of human with
appropriate coverings and clothing but not included to religious monks and sages due to
their religious belief as they do not cover their body with clothing ;
10. We are not concerned here with the wide definition of the word " person",
which in the legal word includes corporations, associations or body of individuals as factually in
these type of cases search of their premises can be done and not of their person. Having regard
to the scheme of the Act and the context in which it has been used in the Section it naturally
21

means a human being or a living individual unit and not an artificial person. The word has to be
understood in a broad commonsense manner and, therefore, not a naked or nude body of a
human being but the manner in which a normal human being will move about in a civilized
society.
Therefore, the most appropriate meaning of the word "person" appears to be "the body of a human being as presented to public view usually with its appropriate
coverings and clothings".

For interpreting the provision, rare cases of some religious monks and
sages, who, according to the tenets of their religious belief do not cover their
body with clothings, are not to be taken notice of.
above definition also referred by the various honble Courts in the following matters ;
{In the Supreme Court of India in the matter CRIMINAL APPEAL Nos. 1158-1159 OF
2004of Union Of India vs Shah Alam & Anr on 11 June, 2009 Author: A Alam Bench: B.
Sudershan Reddy, Aftab Alam}
{In Supreme Court of India in the matter of CRIMINAL APPEAL NO. 1960 OF 2009 of
Jarnail Singh vs State Of Punjab on 11 February, 2011 Bench: B. Sudershan Reddy,
Surinder Singh Nijjar}
{In Delhi High Court in the matter CRL.A.77/2010 of Vinay Kumar & Anr. vs State on 10 July,
2012 Honble Justice Mukta Gupta}
{In Rajasthan High Court in the matter 2007 CriLJ 1734, RLW 2007 (3) Raj 1914 of Ashok
Kumar Sharma vs State Of Rajasthan on 9 February, 2007 Bench: N. K. Jain}
49. That Honble Prime Minister of India Shri Narendra Modi ji, has spoken five times on
protecting the rights of minority communities of India ;
1.

In February 2015, Prime Minister said that ;

Government was committed to protect the right of every individual to adopt
and retain the religion of his choice.

2. Speaking at a gathering of the Christian community in Delhi in February, Modi ji

said that;
My Government will ensure there is complete freedom of faith and that
everyone has the undeniable right to retain or adopt the religion of his or her
choice without coercion or undue influence.
My Government will not allow any religious group, belonging to the majority or
the minority, to incite hatred against others, overtly or covertly. Mine will be a
Government that gives equal respect to all religions.
3.

In a interview with news agency UNI, Modi ji told that ;

Our Constitution guarantees religious freedom to every citizen and that is not
negotiable. I have said this before and I say it again: any discrimination or
violence against any community will not be tolerated,'

4.

Modi ji spoke to a delegation of Muslim leaders that he would be available

even at midnight to address the concerns of the minority community.
22

5.

In an exclusive interview to Time magazine Modi ji said ;

The unity and the integrity of the country are the topmost priorities. All
religions and all communities have the same rights, and it is my responsibility
to ensure their complete and total protection. My government will not
tolerate or accept any discrimination based on caste, creed and religion.

Ref.: {PM gives his word: 5 times Modi spoke up for minority communities,
Hindustan Times, New Delhi| Updated: Jun 03, 2015 18:40 IST}
50.
That under the present circumstances this representation is very much required and
secondly we have no option except to approach your good office for taking immediate action
and direction in this regard being controlling and supervising authority on the whole competent
authorities of prosecution all over India so this representation is being filed to you as the safety
of our holy saints is the supreme law / the ultimate goal of all laws.
51. That Vishwa Jain Sangathan has not filed any petition in this behalf either in honble
Supreme Court of India or before High Court of any State of India.

PRAYER
52.

That the applicant, therefore, pray to the honble President, Prime Minister
and Union Minister of Home Affairs of India may graciously be pleased to;

1.

ISSUE AN ORDER OR DIRECTION TO ALL STATE GOVERNMENTS & UTs AND

HOME DEPARTMENT OR OTHER CONCERN DEPARTMENTS FOR SAFE
MOVEMENT OF JAIN SAINTS AND NON-FILING OF FIR / NOT TAKING
COGNIZANCE ON THE COMPLAINTS MADE AGAINST DIGAMBER SAINTS
DUE TO WALKING NAKED IN ALL STATES & UTs OF INDIA

2.

and / or pass any other order or orders as may be deem fit in the interest
of life and respect of the holy Jain saints.

(SANJAY KUMAR JAIN)

President
Vishwa Jain Sangathan (Regd.)
IX/1983, Lane No. 3,
Kailash Nagar, Delhi 110031
Mob#: 9312278313

Ahimsa Parmo Dharma

Live and let live
23