Quashing of FIRs Under U.P. Conversion Act: Supreme Court's Ruling

Introduction

In a significant ruling, the Supreme Court of India addressed the legality of multiple FIRs filed under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 (U.P. Conversion Act). The Court quashed several FIRs, emphasizing the necessity for competent complainants and the implications of the law on religious conversion. This judgment not only clarifies the procedural aspects of filing FIRs under the U.P. Conversion Act but also underscores the importance of individual autonomy in matters of faith.

Case Background

The case arose from a series of FIRs filed in connection with alleged mass conversions at the Evangelical Church of India in Fatehpur, Uttar Pradesh. The first FIR, No. 224/2022, was lodged by Himanshu Dixit, a member of the Vishwa Hindu Parishad, alleging that a mass conversion of Hindus to Christianity was taking place. Subsequent FIRs were filed by individuals claiming to be victims of the conversion process, alleging coercion and inducement.

The petitioners challenged the validity of these FIRs, arguing that they were filed by individuals not competent to do so under the U.P. Conversion Act. The High Court had previously dismissed petitions seeking to quash these FIRs, leading to the present appeal before the Supreme Court.

What The Lower Authorities Held

The High Court dismissed the petitions on the grounds that the FIRs disclosed cognizable offences and that the subsequent FIRs were not barred by the principles established in T.T. Antony v. State of Kerala, which prohibits multiple FIRs for the same incident. The High Court held that since FIR No. 224/2022 was lodged by a person not competent under the U.P. Conversion Act, the subsequent FIRs were valid.

The Court's Reasoning

The Supreme Court, while examining the petitions, focused on several key issues:

1. **Competency of Complainants**: The Court highlighted that under the unamended Section 4 of the U.P. Conversion Act, only an aggrieved person or their close relatives could lodge an FIR regarding unlawful conversions. Since FIR No. 224/2022 was filed by a person not falling within these categories, it was deemed invalid.

2. **Subsequent FIRs**: The Court noted that FIRs 55/2023 and 60/2023 were filed within a short time frame and were virtually identical to each other and to FIR No. 54/2023. The Court reiterated the principle from T.T. Antony that prohibits multiple FIRs for the same incident, emphasizing that the registration of these FIRs constituted an abuse of process.

3. **Legal Interpretation of the U.P. Conversion Act**: The Court examined the legislative intent behind the U.P. Conversion Act, which aims to protect individuals from coercive conversions while ensuring that only those directly affected can initiate legal proceedings. This interpretation was crucial in determining the validity of the FIRs.

4. **Credibility of Evidence**: The Court scrutinized the evidence collected during the investigations, finding significant discrepancies in witness statements and affidavits. The Court expressed concern over the mechanical nature of the investigations, suggesting that they were conducted to substantiate the FIRs rather than to uncover the truth.

Statutory Interpretation

The Supreme Court's interpretation of the U.P. Conversion Act was pivotal in its ruling. The Act's provisions were designed to restrict the initiation of criminal proceedings to specific individuals, thereby safeguarding personal liberties and preventing frivolous litigation. The Court emphasized that the right to profess, practice, and propagate religion is a fundamental right under Articles 21 and 25 of the Constitution, which must be protected from unwarranted interference.

CONSTITUTIONAL OR POLICY CONTEXT

The ruling also touches upon broader constitutional principles, particularly the right to religious freedom and individual autonomy. The Court underscored that the freedom to choose one's faith is a deeply personal matter, and any legal framework must respect this autonomy. The judgment aligns with previous Supreme Court decisions that have reinforced the importance of individual rights in matters of religion and personal belief.

Why This Judgment Matters

This judgment is significant for several reasons:

1. **Clarification of Legal Standards**: It clarifies the legal standards for filing FIRs under the U.P. Conversion Act, emphasizing the need for competent complainants.

2. **Protection of Individual Rights**: The ruling reinforces the protection of individual rights in matters of religious conversion, ensuring that only those directly affected can initiate legal action.

3. **Prevention of Abuse of Process**: By quashing multiple FIRs for the same incident, the Court aims to prevent the misuse of the legal system for personal vendettas or harassment.

4. **Guidance for Future Cases**: The decision provides a framework for future cases involving the U.P. Conversion Act, guiding lower courts on the interpretation of the law and the handling of FIRs.

Final Outcome

The Supreme Court quashed FIR No. 224/2022 and all consequential proceedings arising therefrom. It also quashed FIR Nos. 55/2023 and 60/2023, emphasizing the need for a single FIR for the same incident. The Court ordered that FIR No. 538/2023 be de-tagged for further consideration regarding the charges under the IPC.

Case Details

• Case Title: Rajendra Bihari Lal and Another vs. State of Uttar Pradesh and Others
• Citation: 2025 INSC 1249
• Court: IN THE SUPREME COURT OF INDIA
• Date of Judgment: 2025-10-17