The Supreme Court allowed the batch of writ petitions and criminal appeals filed by Vice-Chancellor, SHUATS. The Court quashed six FIRs registered under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 (U.P. Conversion Act) and related IPC sections, holding that complaints by persons not “aggrieved” under Section 4 of the Act were invalid.

The petitioners challenged multiple FIRs alleging mass religious conversions of Hindus to Christianity through inducement and fraud. They sought quashing of these FIRs, arguing that these were either repetitive or lodged by persons not legally entitled to complain under the U.P. Conversion Act.

The first FIR alleged that about 90 Hindus were converted to Christianity on 14 April 2022 through inducements such as jobs, education, and healthcare. It was filed by a VHP functionary who had not been personally affected. Other FIRs mirrored these allegations nearly verbatim, often differing only in the names of informants. The Allahabad High Court had observed that the first FIR was barred by Section 4 as it was filed by a non-aggrieved complainant, but other FIRs were allowed.

The petitioners approached the Supreme Court under Articles 32 and 136, seeking quashing of all FIRs and protection of fundamental rights.

The Attorney General argued that the petitioners sought to indirectly undermine the constitutionality of the Act. He argued that Section 4 was merely “enabling,” not restrictive, and any credible information about a cognizable offence could trigger investigation. He also submitted that religious conversions through coercion undermine public order and constitutional morality and justify strict enforcement.

The petitioners argued that FIRs filed by strangers violated Section 4 of the Act and were void ab initio. They also contended that multiple FIRs violated the bar against “second FIRs”. The petitions invoked Article 25 and Article 21 as grounds to protect individual conscience. The petitions also questioned the abuse of criminal law to target Christian institutions and misuse of the statute to initiate multiple FIRs over the same incident.

The Bench comprising Justice J.B. Pardiwala and Justice Manoj Misra delivered a detailed judgement in the matter.

The Court contextualised the Act’s intent to prevent conversion by “misrepresentation, force, undue influence, coercion, allurement, or marriage.” However, it highlighted that Section 4 was enacted deliberately to restrict complaints only to the concerned individual or immediate family. This limited locus standi was meant to prevent misuse and overreach into personal religious decisions.

The Court reaffirmed that freedom of conscience and religion under Article 25, read with Article 21’s protection of individual dignity and autonomy, forms part of the “innermost private sphere” of human choice. The Court drew a constitutional balance between protecting individuals from coercive conversion and safeguarding voluntary conversion decisions as an aspect of personal autonomy.

Rejecting the State’s argument that Section 4 is merely “enabling,” the Court held that when legislature has consciously enacted a restrictive clause, the same cannot be diluted by extending its scope. Thus, the first FIR filed by a VHP functionary was non est, as the complainant was neither victim nor kin. All subsequent “carbon-copy” FIRs were equally invalidated since they stemmed from the same alleged incident.

Though the Court refrained from ruling on the Act’s constitutionality (pending in another bench), it observed that laws against “forced” conversions must be narrowly interpreted to prevent chilling effects on legitimate expressions of faith. Excessive state or societal interference in individual faith decisions risks violating the secular essence of the Constitution.

In result, the Court quashed all FIRs, holding them legally invalid. All consequential proceedings and charge sheets were set aside. One FIR was partly retained for unrelated IPC charges but decoupled from the conversion allegations.

The Court cautioned the State to ensure “scrupulous adherence” to statutory procedure before acting under special laws like the U.P. Conversion Act. The Court further reaffirmed the fundamental right to freedom of religion and the autonomy of personal conscience guaranteed by Articles 21 and 25 of the Constitution.

Cases relied on:

1. State of Haryana v. Bhajan Lal, 1992 Supp (1) 335
2. Anand Kumar Mohatta v. State (NCT of Delhi), (2019) 11 SCC 706

3. T.T. Antony v. State of Kerala, (2001) 6 SCC 181

Cases referred to:

1. Kesavananda Bharati Sripadagalvaru v. State of Kerala, AIR 1973 SC 1461
2. Ratilal Panachand Gandhi v. State of Bombay, AIR 1954 SC 388
3. Saifuddin Saheb v. State of Bombay, AIR 1962 SC 853
4. Commissioner, Hindu Religious Endowments, Madras v. Sri Lakshmindra Thirtha Swamiar of Sri Shirur Mutt, AIR 1954 SC 282
5. K.S. Puttaswamy v. Union of India, (2017) 10 SCC 1
6. Shakti Vahini v. Union of India, (2018) 7 SCC 192
7. Asha Ranjan v. State of Bihar, (2017) 4 SCC 397
8. Shafin Jahan v. Asokan K.M., (2018) 16 SCC 368
9. State of Orissa v. Debendra Nath Padhi, (2005) 1 SCC 568
10. Pepsi Foods Ltd. & Anr. v. Special Judicial Magistrate & Ors., (1998) 5 SCC 749
11. Talab Haji Hussain v. Madhukar Purshottam Mondkar, 1958 SCC OnLine SC 81
12. Rajiv Thapar v. Madan Lal Kapoor, (2013) 3 SCC 330
13. Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra & Ors., (2021) 19 SCC 401
14. R.P. Kapur v. State of Punjab, 1960 SCC OnLine SC 21
15. Bharat Petroleum Corpn. Ltd. v. N.R. Vairamani, (2008) 8 SCC 579
16. Rajbir Singh Dalal v. Chaudhari Devi Lal University, (2008) 9 SCC 284
17. State of A.P. v. Golconda Linga Swamy, (2004) 6 SCC 522
18. Mohammad Wajid v. State of U.P., 2023 SCC OnLine SC 951
19. Imran Pratapgadhi v. State of Gujarat & Anr., 2025 SCC OnLine SC 678
20. Kailashben Mahendrabhai Patel v. State of Maharashtra, 2024 SCC OnLine SC 2621
21. A.M. Mohan v. State, 2024 SCC OnLine SC 339
22. Abhishek v. State of Madhya Pradesh, (2023) 16 SCC 666
23. Joseph Salvaraj A. v. State of Gujarat, (2011) 7 SCC 59
24. Somjeet Mallick v. State of Jharkhand & Ors., (2024) 10 SCC 527
25. Amitbhai Anilchandra Shah v. Central Bureau of Investigation & Anr., (2013) 6 SCC 348
26. Vinod Dua v. Union of India, (2023) 14 SCC 286
27. Priya Prakash Varrier v. State of Telangana, (2019) 12 SCC 432
28. Anju Chaudhary v. State of U.P., (2013) 6 SCC 384
29. Babubhai and Ors. v. State of Gujarat & Ors., (2010) 12 SCC 254
30. Arnab Ranjan Goswami v. Union of India, (2020) 14 SCC 12
31. State of Rajasthan v. Surendra Singh Rathore, 2025 SCC OnLine SC 358
32. Jose Papachen & Anr. v. State of Uttar Pradesh, (2023) SCC OnLine All 804
33. Union of India v. Ashok Kumar Sharma, (2021) 12 SCC 674
34. Rev. Stainislaus v. State of Madhya Pradesh & Ors., (1977) 1 SCC 677

Rajendra Bihari Lal and Anr. vs State of Uttar Pradesh and Ors.

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