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With the advent of Indira Gandhi's emergency and subsequent dissolution of the Congress-led government and the beginning of Devarajaiyam's ongoing confrontation with the Janata Party government that came into power in 1977, the plight of the marginalised in India came to the fore. As a result, Rangarajan, in his book,"Rai Saheb" and its appraisal cited a number of Dalit students who went on hunger strike to (temporarily) suspend their studies as the apex court observed that it must not be lost sight of that behind Dalits were oppressed in society, they were victims of industrial accidents, untouchability and caste-based discrimination, and besides they were denied equality, justice, freedom, liberty, redressal of grievances and access to social services.

On 5 November 1983, the apex court was hearing a public interest litigation (PIL) filed by the Centre for People's Empowerment and Caste Laws (C-PECL) calling on the government to ban untouchability on the ground that it was an article of faith. A Bench of Justices V.K. Ratnam and R.S. Kelkar, rejecting the contention that untouchability is religious, said: "The doctrine that untouchability is a religious principle is a pernicious myth which must be dispelled by the law...Untouchability, in our view, cannot be made a part of the Constitution, and, indeed, it cannot be permitted to continue as a doctrine." Justices Ranjan Gogoi and S.H. Kapadia agreed with the bench.

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