The Supreme Court on Thursday (October 17) quashed multiple FIRs and criminal proceedings filed under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 against the Vice-Chancellor and senior officials of Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS), Prayagraj, in cases alleging mass religious conversions to Christianity.

The petitions—filed under Article 136 as Special Leave Petitions against the Allahabad High Court’s refusal to quash the FIRs, and under Article 32 for consolidation and protection—challenged multiple FIRs lodged across Uttar Pradesh against Vice-Chancellor Dr. Rajendra Bihari Lal, Director Vinod Bihari Lal, and other university staff.

A Bench comprising Justice J.B. Pardiwala and Justice Manoj Misra delivered the verdict, summarizing its conclusions as follows:

(a) FIR No. 224/2022 (Kotwali PS, Fatehpur) was quashed for being filed by a person not legally competent under the UP Conversion Act, rendering it incurably defective.

(b) FIR Nos. 55/2023 and 60/2023 (Kotwali PS) were struck down as barred by the TT Antony principle prohibiting multiple FIRs for the same incident.

(c) The Court reaffirmed that writ petitions under Article 32 for quashing FIRs are maintainable in exceptional cases. FIRs 224/2022 and 47/2023 were accordingly quashed.

(d) FIR No. 54/2023 was also set aside, the Court noting that the investigation lacked bona fides and failed to inspire confidence.

(g) With respect to FIR No. 538/2023, the Court held that no offence under the UP Conversion Act was made out, though allegations under IPC Sections 307, 386, and 504 would require further hearing. The interim protection to the accused will continue.

The FIRs—224/2022, and 47, 54, 55, and 60 of 2023—had invoked offences under IPC Sections 153A, 506, 420, 467, 468, and 471, as well as Sections 3 and 5(1) of the UP Conversion Act, 2021.

The Supreme Court had earlier granted interim protection from arrest to the accused in December 2023, staying coercive action in related cases. During a hearing in May 2024, the Bench had remarked that certain provisions of the UP law appeared to contravene Article 25 (freedom of religion) of the Constitution.

Senior Advocate Siddharth Dave represented the petitioners, while Attorney General R. Venkataramani and AAG Garima Prashad appeared for the State of Uttar Pradesh.

The petitioners contended that as members of a religious minority, they were being systematically targeted by the State government. They argued that the FIRs were politically motivated, legally unsustainable, and intended to disrupt the university’s operations. According to them, the allegations of forced or allured conversions were baseless, with multiple FIRs registered in different districts over the same set of facts.

It was further submitted that the FIRs formed part of “a coordinated and malicious campaign” to suppress their constitutional rights under Articles 25, 29, and 30. Relying on Arnab Ranjan Goswami v. Union of India (2020) and Satinder Singh Bhasin v. GNCTD (2019), they argued that multiple FIRs for the same cause of action violate the right to personal liberty, and that the Court can quash or consolidate them under Article 32.

Attorney General Venkataramani, assisting the Court, emphasized that while the UP Conversion Act must be interpreted broadly, prosecutions should not be “unfair or arbitrary.” He submitted that the FIRs disclosed cognizable offences, citing evidence allegedly seized from SHUATS premises, including Aadhaar card printing equipment and forged identity documents purportedly used to facilitate conversions.

Referring to Sections 3 and 4 of the UP Conversion Act, the AG explained that the law prohibits conversions by force, misrepresentation, or allurement, and that “aggrieved persons” such as relatives are legally entitled to file complaints. He clarified that, barring one exception, the FIRs in question were filed by such aggrieved persons.

A constitutional challenge to the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021—filed by Citizens for Justice and Peace and Jamiat Ulema-i-Hind—remains pending before the Supreme Court.

Case Title: Rajendra Bihari Lal and Anr. v. State of Uttar Pradesh and Ors.

W.P. (Crl.) No. 123/2023 & connected cases