Allahabad: The Allahabad High Court dismissed a writ petition filed by a Muslim student seeking permission to wear a headscarf alongside her prescribed uniform at a private unaided educational institution, ruling that wearing a hijab inside the classroom is not an “essential religious practice” under Article 25 of the Constitution. A division bench comprising Justice J.J. Munir and Justice Indrajeet Shukla held that educational institutions have the legal autonomy to enforce a uniform, non-discriminatory dress code to maintain discipline, equality, and institutional identity.
The ruling came in the case of Sukaina Rizvi v. State of U.P. and Others, filed by a minor student who was denied admission to Class XI at Tagore Public School in Attarsuiya, Prayagraj, after she insisted on wearing a headscarf. The petitioner argued that she had been permitted to wear the headscarf from Classes VI to X without objection and contended that prohibiting it violated her constitutional rights to freedom of expression, dignity, and religious practice under Articles 14, 19(1)(a), and 25. However, the school management maintained that it enforces a uniform dress code for all students regardless of community to foster a religion-neutral environment, arguing that granting subjective exemptions would undermine administrative authority and discipline.
Rejecting the petitioner’s arguments, the court observed that prior inaction or indulgence by a school administration does not grant a student a vested, enforceable legal right to demand modifications to a dress code. The bench noted that the petitioner failed to present sufficient religious texts or authoritative material to establish that wearing a headscarf inside a classroom is an indispensable obligation of her faith. Drawing support from previous judicial precedents—including the 2022 Karnataka High Court full-bench judgment—the Allahabad High Court emphasized that so long as a uniform policy is bona fide and non-discriminatory, the primary domain of defining student attire rests strictly with the institution.
