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- Many of those who aren’t religious today are considered a tinok she’nishba because they were raised with faulty beliefs. Other poskim are hesitant to apply tinok shenishba to many irreligious Jews today.
- We mourn over the loss of a Jew who wasn’t religious nowadays. 
- Rambam Mamrim 3:3, Darkei Moshe 159:3, Chazon Ish YD 2:28, Shivat Tzion Chadashot 23, Chazon Ovadia Aveilut v. 1 p. 538, Emet LYakov 345:218, Melamed Lhoil 29
- See Igrot Moshe 2:50-51, 3:12. See at much greater length: https://orot.ac.il/sites/default/files/9-10.pdf
- Chazon Ovadia Aveilut v. 1 p. 538. His three reasons are the perhaps he did teshuva (Yad Yitzchak 3:149), perhaps avoiding mourning would lead to ayvah (Maharshag YD 1:25:6), and perhaps he was a tinok she’nishba (Emet LYakov 345:218).