Pasha quotes from Shirur Mutt : "The Attorney-General lays stress upon clause (2)(a) of the article and his contention is that all secular activities, which may be associated with religion but do not really constitute an essential part of it, are amenable to State regulation".

Pasha says the above argument was not accepted by the Court in Shirur Mutt. Quotes "The contention formulated in such broad terms cannot, we think, be supported".