Supreme Court Curbs ‘Travesty of Justice,’ Quashes Multiple FIRs Under UP Anti-Conversion Law

New Delhi – In a landmark judgment that reinforces constitutional safeguards against the misuse of criminal law, the Supreme Court of India has quashed a series of First Information Reports (FIRs) filed under Uttar Pradesh's controversial anti-conversion law. The ruling, delivered in the case of Rajendra Bihari Lal and Anr. v. State of U.P. and Ors. , provides a critical clarification on the scope of the legislation, asserting that routine religious gatherings and charitable activities do not constitute criminal offenses.

A bench comprising Justices J.B. Pardiwala and Manoj Misra delivered the comprehensive 158-page judgment, excoriating the state's investigative process and concluding that the continuation of criminal proceedings against officials of the Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS) would amount to a "travesty of justice." The Court found the allegations of mass forced conversion to be based on "completely incredulous material" and deemed the multiple FIRs a blatant abuse of the legal process.

“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 bench stated, setting a powerful precedent for lower courts and law enforcement agencies dealing with similar cases.

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Background: A Barrage of Allegations Against a Minority Institution

The petitions were filed by Dr. Rajendra Bihari Lal, the Vice-Chancellor of SHUATS, a century-old Christian minority institution in Prayagraj, along with other university officials. They faced a volley of six FIRs lodged between December 2021 and January 2023 in Fatehpur and other districts. The charges invoked sections of the Indian Penal Code, including attempt to murder and extortion, alongside the stringent provisions of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021.

The primary accusation, first leveled in an FIR by Himanshu Dixit, a Vishwa Hindu Parishad (VHP) office-bearer, claimed that 90 Hindus were illicitly converted to Christianity during a Maundy Thursday gathering at the Evangelical Church of India on April 14, 2022. The complaint alleged that attendees were lured with financial incentives and other inducements. This was followed by several other FIRs, often filed in quick succession, recycling the same core allegations.

Court’s Scathing Indictment of the Investigation

The Supreme Court undertook a meticulous examination of each FIR and the evidence collected, uncovering a litany of procedural flaws and evidentiary deficiencies. The judgment highlighted that the investigation seemed aimed not at discovering the truth but at substantiating preconceived notions.

"The entire process of investigation was not an attempt to uncover the truth of the allegations, but rather to find ways to somehow substantiate the allegations levelled in the FIR," the Court observed.

Key findings that led to the quashing of the FIRs include:

• Statutory Bar on Third-Party Complaints: The Court held that the initial and most significant FIR (No. 224/2022) was legally invalid from its inception. It was filed by a third-party activist, whereas Section 4 of the UP Conversion Act (prior to a 2024 amendment) explicitly restricted the right to lodge a complaint to the alleged victim or their immediate relatives. The bench affirmed the legal principle that a special law's specific provisions override general criminal procedure, thereby dismissing the State's argument that anyone could file an FIR.

• Impermissibility of Multiple FIRs: The subsequent FIRs were found to be a tactical maneuver to overcome the legal defect of the first one. Applying the principle laid down in T.T. Antony v. State of Kerala , the Court ruled that registering multiple FIRs for the same alleged incident is an abuse of investigative power and exposes the accused to undue harassment.

• Fabricated and 'Cyclostyled' Evidence: The bench was particularly critical of the quality of witness statements, describing them as "mechanically reproduced." It pointed to absurdities where different witnesses gave identical, word-for-word testimonies, including typographical errors and factual mix-ups. For instance, multiple witnesses with different original names claimed their names were changed to the same new name, "Rajesh Kumar Samson," exposing the fabricated nature of the evidence.

Religious Gatherings and Charity Are Not Crimes

In a significant clarification with far-reaching implications, the Supreme Court declared that the UP Conversion Act does not criminalize ordinary religious and charitable work. This addresses a major concern among civil society and minority groups that the law could be weaponized to suppress constitutionally protected activities.

"We do not find from a reading of the U.P. Conversion Act that organization of religious gatherings or doing charity work in the name of religion has also been made a criminal offence. No provision in the IPC prohibits such activities too," the bench unequivocally stated.

The Court examined the prosecution's "evidence," which included videos of prayer meetings and Bible readings, and found no element of coercion, fraud, or allurement as defined by the Act. It dismissed the notion that citing a Bible verse, such as Psalm 2:8, could be construed as an illegal inducement.

Upholding Fundamental Rights via Article 32

The State had argued that the petitioners should have sought remedies in lower courts before approaching the Supreme Court directly under Article 32. The bench firmly rejected this, asserting its constitutional duty to protect fundamental rights. It held that in extraordinary circumstances, particularly where the grievance stems from a direct violation of fundamental rights and an abuse of legal process, the Supreme Court is not only empowered but obligated to intervene.

Implications for Anti-Conversion Jurisprudence

This judgment is being hailed by legal experts as a "watershed moment" that will curb the misuse of anti-conversion laws, which have been enacted in several states. Senior Advocate S. Mohammed Haider Rizvi noted that the ruling "sets a precedent for judicial intervention against misuse of special legislation, reinforcing the principle that constitutional safeguards of personal liberty and religious freedom must not be diluted by motivated or frivolous litigation."

The decision is expected to:

1. Prompt Reassessment of Pending Cases: It will likely influence the adjudication of similar cases pending in Uttar Pradesh and other states, compelling courts to apply stricter scrutiny to the evidence and procedural compliance.
2. Guide Law Enforcement: The judgment serves as a clear directive to police forces to conduct genuine, unbiased investigations rather than seeking to merely validate allegations made in an FIR.
3. Protect Minority Rights: By drawing a clear line between legitimate religious practice and unlawful conversion, the verdict provides a degree of protection to minority communities engaged in religious, educational, and charitable activities.

While the Supreme Court has set a high bar for prosecution under the UP Conversion Act, it also de-tagged one FIR involving distinct allegations for separate consideration, indicating that its intervention is tailored to the specific facts of each case. Nonetheless, the core message is unambiguous: the machinery of criminal justice cannot be deployed to settle political scores or harass citizens, and the judiciary will stand as the ultimate guardian of due process and liberty.