Supreme Court Quashes Multiple FIRs Under UP Conversion Law, Says Law Can’t Harass Innocents

October 18, 2025: Emphasising that criminal law must not serve as a means to harass innocent citizens, the Supreme Court on Friday, 17 October, quashed several FIRs filed in Uttar Pradesh’s Fatehpur district over alleged “mass religious conversions” of Hindus to Christianity.

In a significant ruling on the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, a Bench of Justices J.B. Pardiwala and Manoj Misra set aside five First Information Reports against several individuals, including Rajendra Bihari Lal, Vice-Chancellor of Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS).

Justice Pardiwala, who authored the 158-page judgement, noted that the FIRs were marred by legal flaws, procedural errors, and lacked credible evidence. The Court ruled that continuing such prosecutions would amount to a “travesty of justice.”

‘Criminal Law Cannot be made a Tool of Harassement’

“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 verdict stated, referring to “glaring infirmities” in one of the 2022 FIRs.

Citing one such case, the judgement observed: “It was not open to the police to overcome the difficulty by getting persons with vested interests to make complaints regarding the same alleged incident after a considerable delay and thereafter initiate a fresh round of investigation against largely the same set of accused persons. Unfortunately, this is the only impression which the material on record has left on us.”

The Bench dismissed arguments that the Supreme Court should refrain from quashing the FIRs under Article 32 of the Constitution (right to move the Supreme Court for enforcement of fundamental rights).

“This court, as the highest constitutional court, has been conferred with the powers as enshrined under Part III of the Constitution to provide remedies against the violation of fundamental rights... Once the Constitution has cast such a responsibility upon it, this Court need not direct a petitioner to pursue an alternative remedy, when the grievance stems from the alleged violation of a fundamental right,” it stated, adding that the extraordinary circumstances warranted quashing the FIRs.

The Bench examined each FIR in detail and pointed out significant deficiencies, including the fact that no alleged victim of conversion had approached the police with a complaint.

Detagging of Pleas

However, the Court ordered the detagging of pleas related to one of the six FIRs, noting that it involved separate offences. It directed that the interim protection earlier granted to the accused would remain in effect until the matter was finally resolved.

Quoting earlier judgments, the Bench said, “Where the High Court is satisfied that the process of any court is being abused or likely to be abused or that the ends of justice would not be secured, it is not only empowered but also obligated under the law to exercise its inherent powers...”

The Court further stated that the Uttar Pradesh law, being a special legislation, prescribed certain procedural norms distinct from the Code of Criminal Procedure (CrPC).

“It is a settled position of law that the intention of the legislature should be construed from the plain text of the statute, and if the plain interpretation does not result into any absurdity or is not unworkable, then the courts should not depart from the meaning which is manifest from the plain text,” it said.

Addressing the credibility of witness statements, the judgement noted, “Neither the witnesses underwent unlawful religious conversion, nor were they present at the place of the alleged mass conversion dated April 14, 2022.” Referring to a previous ruling, the Court quashed an FIR, observing that “the existence of multiple FIRs for the same alleged incident stamps an abuse of investigative powers.”

The Bench concluded that repeated filing of FIRs for the same occurrence “undermines the fairness of the investigative process and exposes the accused to unwarranted harassment.”

The petitions concerned six FIRs lodged between December 2021 and January 2023 under various provisions of the IPC and the Uttar Pradesh law.

One FIR, registered on 15 April 2022 at Kotwali police station in Fatehpur district, was based on a complaint by Himanshu Dixit, vice-president of the Vishwa Hindu Parishad, against 35 named and 20 unidentified individuals. He alleged that at an event held at the Evangelical Church of India a day earlier—on Maundy Thursday, a day of religious significance for Christians—90 Hindus were converted to Christianity.

The complaint claimed that the alleged converts were subjected to undue influence, coercion, and lured by false promises and financial incentives.

The accused faced charges under Sections 307 (attempt to murder), 504 (intentional insult intended to provoke breach of peace), and 386 (extortion) of the Indian Penal Code, along with offences under the anti-conversion law.

Source: The Hindu