See this calender of an Indian state called Assam. It has 35 holidays. The state offers 2 days parental holiday as well. Parental holiday and 35 makes it 37. There are also 2 half days, which I am not counting.
India has 2 days restricted holidays provision where if an employee choose may take holiday on any such two days of the year. A Christian can take restricted holiday on 24 December (Christmas Eve), a Hindu may take one on Shivratri and other festivals, a Muslim may take one on Muharram. These holidays are like leaves and are not counted as general leaves (casual, commuted, or earned). These 2 with 37 makes 39.
There is almost always a local holiday in that state, that power lies with the district commissioner. That makes it 40.
So, it gives 35 + 2 (parental) + 2 (restricted) + 1 (local) = 40 days.