In the landmark Bijoe Emmanuel vs. State of Kerala case (1986) involving Jehovah’s Witnesses, the Supreme Court held that the right to remain silent respectfully during the singing of the National Anthem is protected under which combination of constitutional provisions?

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In Bijoe Emmanuel vs. State of Kerala (1986), three students were expelled for refusing to sing the National Anthem due to their religious beliefs, though they stood up respectfully. The Supreme Court reversed the expulsion, holding that compelling them to sing violates both freedom of expression under Article 19(1)(a) (which includes the right to remain silent) and freedom of conscience and religion under Article 25(1), as their refusal was based on genuine, conscientious religious tenets.

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