Introduction:
In a landmark judgment reaffirming the rule of law and protection against arbitrary criminal prosecution, the Supreme Court in Rajendra Bihari Lal and Another v. State of Uttar Pradesh and Others, W.P. (Crl.) No. 123 of 2023, reported as 2025 LiveLaw (SC) 1021, quashed multiple FIRs lodged in Uttar Pradesh under the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021 and corresponding IPC provisions. The bench comprising Justice J.B. Pardiwala and Justice Manoj Misra held that the FIRs against Dr. Rajendra Bihari Lal, Vice-Chancellor of Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS), and other university officials, were founded upon “completely incredulous material” and amounted to a blatant misuse of criminal law. The Court observed that the series of FIRs—filed in different police stations but revolving around identical allegations of “mass religious conversion”—were legally unsustainable, riddled with procedural infirmities, and motivated by ulterior intent. It ruled that the criminal process cannot be allowed to degenerate into a tool for harassment, especially when the evidence on record failed to disclose any act amounting to an offence under the UP Conversion Act or the Indian Penal Code. The judgment sends a strong message that religious gatherings, charitable works, and spiritual preaching cannot be criminalized in the absence of credible evidence of coercion, inducement, or fraudulent intent.
Arguments of the Petitioners:
The petitioners, led by Dr. Rajendra Bihari Lal, the Vice-Chancellor of SHUATS, along with other officials and associates of the institution, challenged a series of FIRs registered in various districts of Uttar Pradesh, particularly in Fatehpur and Prayagraj, between 2022 and 2023. The petitioners contended that the FIRs were motivated, repetitive, and devoid of factual or legal basis, amounting to a gross abuse of criminal law. It was argued that the primary allegations related to religious gatherings, preaching of the Bible, and charity activities carried out under the aegis of the university’s social and spiritual outreach programs—activities which were constitutionally protected under Articles 25 and 26 guaranteeing the freedom of religion and propagation of faith.
The petitioners further contended that the first FIR (No. 224/2022) was lodged by a third party, one Himanshu Dixit, the Vice-President of the Vishwa Hindu Parishad, who was not a victim or aggrieved person under the law. They emphasized that Section 4 of the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021, as it stood before the 2024 amendment, explicitly restricted the right to lodge a complaint to victims of alleged illegal conversion or their immediate relatives. Thus, the very institution of the first FIR was barred by statute and liable to be quashed.
Additionally, the petitioners demonstrated that the subsequent FIRs (Nos. 54/2023, 55/2023, and 60/2023) were mere reproductions of the same allegations—often lodged within minutes or days of each other—indicating a deliberate design to keep the accused under continuous harassment. The statements of witnesses across these FIRs were shown to be “cyclostyled” or mechanically reproduced, even repeating typographical errors and mismatched names, exposing the lack of genuine investigation. For instance, several witness statements absurdly claimed that their names were changed to “Rajesh Kumar Samson,” revealing that portions of statements were copied verbatim from one another.
The petitioners also argued that the so-called evidence of illegal conversions—such as video recordings—merely showed religious meetings and charity drives, which are legitimate expressions of faith and social service. They argued that no inducement, coercion, or fraudulent representation was ever alleged or proved. Moreover, the subsequent FIRs appeared to have been orchestrated to circumvent the legal defect of the first FIR’s maintainability.
The defense further submitted that the FIRs were politically motivated and intended to malign the university and its administration under the garb of anti-conversion law enforcement. It was pointed out that SHUATS is a century-old Christian minority institution engaged in agricultural and technological education, with a well-documented record of interfaith harmony. The repeated invocation of the UP Conversion Act, they argued, was a targeted misuse to intimidate Christian institutions and individuals engaging in religious or humanitarian activities.
In conclusion, the petitioners urged the Supreme Court to invoke its inherent powers under Article 32 to prevent miscarriage of justice and quash all proceedings initiated on such patently false and frivolous grounds. They relied on precedents such as State of Haryana v. Bhajan Lal and T.T. Antony v. State of Kerala, which lay down principles governing the quashing of FIRs where the allegations do not constitute an offence or are manifestly malafide.
Arguments of the Respondents:
The State of Uttar Pradesh, represented by Attorney General for India R. Venkataramani and AAG Garima Prashad, opposed the petitions, asserting that the FIRs disclosed cognizable offences under the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021, and therefore warranted investigation. The State argued that while the Act originally restricted who could file a complaint, the general powers under Section 154 CrPC permitted the registration of an FIR by any individual aware of the commission of an offence. The Attorney General maintained that procedural irregularities should not automatically nullify the substance of the allegations and that the petitioners ought to face investigation if there was any suspicion of inducement or fraudulent conversion.
The State further contended that the pattern of activities at the university indicated the systematic use of religion for inducement, including promises of financial aid, employment, and social benefits. It was argued that whether these amounted to “allurement” under Section 3 of the UP Act was a matter of investigation and not for summary quashing. The State also relied on certain witness statements alleging that individuals were persuaded to convert by citing verses from the Bible, which, in the prosecution’s view, constituted indirect inducement.
Moreover, the State’s counsel defended the filing of multiple FIRs, arguing that each represented a distinct set of victims and complainants. The government maintained that public order implications justified stringent scrutiny under the anti-conversion law and that premature quashing of FIRs would send a wrong signal, undermining the State’s legitimate interest in maintaining communal harmony.
However, when confronted by the Court regarding the repetition of witness statements, errors in names, and lack of original evidence of conversion, the State failed to provide satisfactory explanations. It also could not demonstrate that any of the alleged victims had formally converted or filed affidavits affirming coercion, inducement, or deceit.
Court’s Findings and Judgment:
The Supreme Court, after examining the FIRs, the investigation materials, and the legislative framework of the U.P. Conversion Act, delivered a strongly worded judgment quashing multiple FIRs. It began by emphasizing that criminal law must not become an instrument of persecution, nor can it be used to intimidate individuals based on religion.
The Court first addressed the statutory bar under Section 4 of the UP Conversion Act (prior to the 2024 amendment), holding that the first FIR (No. 224/2022) was legally incompetent, as it was filed by a third party not recognized as a “victim” under the Act. Rejecting the Attorney General’s argument that the general law under CrPC should override the special provision of the UP Act, the Court held that special law prevails over general law, and the legislative intent was clear—to prevent vexatious third-party complaints by “busybodies” seeking to weaponize the law.
Next, the bench examined the quality of evidence collected by the investigating agencies and found it to be woefully inadequate and lacking credibility. The Court observed that the witness statements were mechanically reproduced, filled with identical language and factual errors, indicating a complete absence of genuine investigation. Illustratively, several witnesses purportedly had different names but identical narratives—an unmistakable sign of fabrication. The Court found that none of the witnesses had actually undergone conversion, nor had any of them alleged coercion, fraud, or inducement.
The bench scrutinized the videos and photographic materials presented by the prosecution, which merely depicted religious gatherings, prayers, and Bible readings. The Court categorically held that organizing religious meetings, preaching, or engaging in charity in the name of religion are not offences under either the UP Conversion Act or the Indian Penal Code. It further noted that no irregularities in funding or foreign donations were demonstrated, and even if such existed, they would fall under separate laws, not the anti-conversion statute.
On FIR 47/2023, the Court found the allegations baseless, observing that the supposed “evidence of inducement” was merely a Bible verse—Psalm 2:8, which reads, “Ask me, and I will make the nations your inheritance, the ends of the earth your possession.” The Court stated, “We are at a loss to understand how such a verse, cited in a religious gathering, could amount to inducement or unlawful conversion.”
With respect to FIRs 54/2023, 55/2023, and 60/2023, the Court applied the principle in T.T. Antony v. State of Kerala (2001), ruling that multiple FIRs over the same incident are impermissible. It noted that these FIRs were filed to circumvent the illegality of the first FIR, often within minutes of each other, and relied on identical evidence. The Court condemned the duplicity and mechanical nature of the investigations, observing that “the entire process appeared to be an attempt not to uncover the truth but to somehow substantiate preconceived allegations.”
Regarding FIR 54/2023, the Court pointed to glaring inconsistencies. The complainant, who claimed to be a victim of unlawful conversion, had earlier appeared as a witness in FIR 224/2022, denying any such conversion and identifying himself as a member of the VHP who visited the venue out of curiosity. The Court remarked that such contradictory conduct “makes it an easy guess” that subsequent FIRs were orchestrated by vested interests to keep the controversy alive.
In FIR 538/2023, which combined allegations of illegal conversion with claims of extortion and threats, the Court partially quashed the FIR—removing charges under the UP Conversion Act—and adjourned consideration of the other IPC allegations for further hearing.
The bench concluded that the materials on record were wholly insufficient to justify prosecution, declaring: “The criminal law cannot be allowed to be made a tool of harassment of innocent persons, allowing prosecuting agencies to initiate prosecution at their whims and fancy, on the basis of completely incredulous material.” The Court held that when investigative materials lack genuineness and credibility, continuation of criminal proceedings would amount to an abuse of process and a violation of Article 21 rights.
Accordingly, all FIRs—Nos. 224/2022, 47/2023, 54/2023, 55/2023, 60/2023, and 538/2023 (partly)—were quashed. The judgment stands as a significant reaffirmation of constitutional safeguards against arbitrary use of criminal law, reinforcing that faith and religious expression cannot be criminalized in the absence of clear evidence of coercion or fraud.