The Research Dialogue

Abstract

Religious freedom is one of the most fundamental human rights recognized in democratic constitutional systems across the world. Different nations, however, adopt different constitutional and legal approaches to regulate the relationship between religion and the State. The United States follows a strict separation model based on the Establishment Clause and Free Exercise Clause of the First Amendment. France adopts the doctrine of laïcité, emphasizing strict secularism and exclusion of religion from the public sphere. India follows a unique model of positive secularism that permits State engagement with religion to ensure equality, reform, and social justice. This research paper undertakes a comparative analysis of religious freedom in the United States, France, and India. It examines constitutional provisions, judicial interpretations, secular philosophies, landmark cases, and contemporary challenges relating to religious liberty. The paper further evaluates the strengths and limitations of each model and argues that the protection of religious freedom must balance individual liberty, public order, equality, and constitutional morality. The study concludes that despite differences in constitutional traditions, all three democracies continue to struggle with tensions between religious liberty and State regulation in increasingly pluralistic societies.

Keywords: Religious Freedom, Secularism, Laïcité, Constitutional Law, Human Rights, Comparative Constitutionalism, First Amendment, Indian Secularism.