This Supreme Court judgment quashed multiple FIRs under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, holding that the unamended Section 4 restricted lodging of complaints only to aggrieved persons or their relatives. The Court found the subsequent FIRs were impermissible as they pertained to the same incident, violated the principle against multiplicity of proceedings, and were an abuse of process.
Facts Of The Case:
The case involves a batch of petitions and appeals concerning six FIRs registered under the Indian Penal Code and the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021. The primary FIR (No. 224/2022) was lodged on 15.04.2022 at the instance of Himanshu Dixit, a Vice President of the Vishwa Hindu Parishad, alleging mass religious conversion at the Evangelical Church of India, Fatehpur. Subsequent FIRs (Nos. 47, 54, 55, and 60 of 2023) were registered by different individuals claiming to be victims of unlawful conversion on 14.04.2022 and 25.12.2021, while FIR No. 538/2023 involved separate allegations of assault and threat. The accused, including the petitioners (university officials and others), challenged these FIRs, arguing they were based on complaints by incompetent persons under the unamended Section 4 of the U.P. Conversion Act, were multiple FIRs for the same incident, and were lodged with mala fide intent after inordinate delay. The High Court dismissed their quashing petitions, leading to appeals before the Supreme Court, which examined the legality of the FIRs and the investigative process.
Procedural History:
The procedural history began with the registration of six FIRs in Uttar Pradesh between 2022 and 2023. The accused persons filed multiple writ petitions before the Allahabad High Court under Article 226 of the Constitution and Section 482 of the CrPC, seeking to quash these FIRs. The High Court, in a series of judgments dated between February 2023 and April 2024, dismissed all petitions, upholding the validity of the FIRs. Subsequently, the petitioners filed Special Leave Petitions before the Supreme Court, which were converted into Criminal Appeals. Additionally, three writ petitions were filed directly before the Supreme Court under Article 32 of the Constitution, challenging FIRs that had not been previously contested before the High Court. The Supreme Court clubbed all these matters and, after hearing arguments, delivered the present judgment, ultimately quashing the impugned FIRs and all consequential proceedings.
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Court Observation:
In its observations, the Supreme Court underscored the fundamental right to privacy and personal autonomy in matters of faith and religious choice, inherent in Articles 21 and 25 of the Constitution. The Court interpreted the unamended Section 4 of the U.P. Conversion Act as a restrictive provision, permitting only the aggrieved individual or their close relatives to lodge an FIR for unlawful conversion, thereby protecting this private sphere from interference by unrelated third parties. It held that FIR No. 224/2022, lodged by a member of a religious organization, was legally invalid for non-compliance with this provision. Applying the principle from T.T. Antony v. State of Kerala, the Court found that the subsequent FIRs (Nos. 54, 55, and 60 of 2023) pertaining to the same alleged incident of mass conversion on 14.04.2022 were impermissible multiple FIRs, amounting to an abuse of process. It also noted glaring inconsistencies, cyclostyled witness statements, and a lack of bona fides in the investigation, which collectively rendered the continuation of proceedings a travesty of justice.
Final Decision & Judgement:
The Supreme Court allowed the appeals and writ petitions, quashing all six impugned FIRs (Nos. 224/2022, 47/2023, 54/2023, 55/2023, 60/2023, and 538/2023) and all consequential criminal proceedings arising therefrom. The Court held that FIR No. 224/2022 was invalid ab initio as it was lodged by a person not competent under the restrictive unamended Section 4 of the U.P. Conversion Act. It further ruled that the subsequent FIRs (Nos. 54, 55, and 60 of 2023) for the same incident were impermissible multiple FIRs barred by the principle laid down in T.T. Antony. Finding the entire investigative process vitiated by mala fides, cyclostyled evidence, and grave inconsistencies, the Court concluded that allowing the proceedings to continue would be an abuse of the process of law and a miscarriage of justice.
Case Details:
Case Title: Rajendra Bihari Lal and Another Versus State of Uttar Pradesh and Others Citation: 2025 INSC 1249 Criminal Appeal No(s).: Writ Petition (Crl.) Nos. 123, 141, and 315 of 2024. Date of Judgement:17th October, 2025 Judges/Justice Name: Justice J.B. Pardiwala
Download The Judgement Here