In a comprehensive judgment that scrutinizes the application of anti-conversion laws and safeguards against misuse of criminal processes, the Supreme Court of India has quashed several First Information Reports (FIRs) lodged under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 (U.P. Conversion Act) and various sections of the Indian Penal Code (IPC). The ruling, delivered on October 17, 2025, addresses allegations of unlawful mass religious conversions in Fatehpur district, providing significant relief to petitioners including Rajendra Bihari Lal, Vice-Chancellor of Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS), and associated individuals. The court emphasized the need to prevent harassment through frivolous prosecutions while upholding constitutional protections under Articles 21 and 25.
The batch of matters involved writ petitions and appeals challenging six FIRs registered between April 2022 and December 2023, primarily at Kotwali Police Station, Fatehpur. These FIRs accused the petitioners of orchestrating illegal conversions through inducements, fraud, and force, often linked to events at a local church or mission hospital. Key allegations included mass conversions of about 90 Hindus during a prayer meeting on April 14, 2022, and subsequent claims of threats and extortion.
Justice J.B. Pardiwala, authoring the 157-page verdict with Justice Manoj Misra concurring, dissected the U.P. Conversion Act’s scheme, particularly the unamended Section 4, which restricted complaints to victims, their family, or prescribed persons. The court found FIR No. 224/2022 invalid as it was filed by an unrelated informant from a Hindu organization, not a competent complainant. Subsequent FIRs (Nos. 47/2023, 54/2023, 55/2023, 60/2023) were deemed attempts to circumvent this defect, violating principles against multiple FIRs for the same incident as laid down in T.T. Antony vs. State of Kerala (2001).
For FIR No. 538/2023, the court quashed charges under the Conversion Act but de-tagged IPC offenses (attempt to murder, extortion) for separate hearing, citing incomplete records and affidavits alleging fabricated witness statements. The bench reiterated that quashing under Article 32 is permissible in extraordinary cases to prevent abuse of process, even post-chargesheet, if allegations lack credibility or prima facie evidence.
The judgment critiques investigative lapses, including delayed complaints, inconsistent statements, and potential mala fides, noting that criminal law cannot be a “tool of harassment.” It clarifies that while freedom of religion allows propagation, it prohibits coercive conversions. Legal experts view this as a bulwark against overzealous enforcement of anti-conversion laws, potentially influencing similar cases in other states.
Petitioners argued the FIRs were politically motivated to target Christian institutions, while the state defended them as necessary to curb illegal proselytization. The court granted interim protections and directed de-tagging for one SLP, underscoring judicial vigilance in protecting personal liberties.
This verdict may deter blanket prosecutions under conversion laws, reinforcing that complaints must adhere to statutory mandates and investigations maintain integrity.
Case Details:
- Case Title: Rajendra Bihari Lal and Another vs. State of Uttar Pradesh and Others (and connected matters)
- Citation: 2025 INSC 1249
- Court: Supreme Court of India (Criminal Original/Appellate Jurisdiction)
- Petition/Appeal Numbers: Writ Petition (Crl.) No. 123/2023 (lead); includes WP (Crl.) Nos. 141/2023, 315/2024; Criminal Appeal Nos. 4565-4578/2025 (arising from SLP (Crl.) Nos. 7233-7235/2023, etc.)
- Judges: Justice J.B. Pardiwala and Justice Manoj Misra
- Date of Judgment: October 17, 2025
- Key Issue: Validity and quashing of FIRs under U.P. Conversion Act and IPC for alleged unlawful religious conversions.
- Outcome: FIRs Nos. 224/2022, 47/2023, 54/2023, 55/2023, 60/2023 quashed; Conversion Act charges in FIR 538/2023 quashed, IPC portions de-tagged; petitions/appeals allowed.
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