Under the Indian Constitution, the right to remain silent — for example, the right not to be compelled to sing the National Anthem when religious conscience objects — was recognised by the Supreme Court as part of Article 19(1)(a) in which case?

1. **Bijoe Emmanuel v. State of Kerala, (1986) 3 SCC 615** held that a government circular having no legal sanction violates Article 19(1)(a) if it compels each and every pupil to join in the singing of the National Anthem despite his genuine, conscientious religious objection. 2. The case is the **leading authority on the right not to speak** as a facet of free speech under Article 19(1)(a). 3. *S.P. Gupta* gives us the right to receive and impart information; *Sakal Papers* protects the press against circulation-throttling regulation; *Cricket Association of Bengal* is the airwaves-belong-to-public-trust case on broadcasting. 4. Each of those expands the speech right, but the **right to remain silent** is specifically the Bijoe Emmanuel contribution. _Source: ICSI CS Executive — Lesson 2, Article 19(1)(a) discussion, p. 40 ¶3._