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Rajendra Bihari Lal & Anr. vs. State of Uttar Pradesh & Ors.

Not available · 2025 INSC 1249Decided 17 Oct 2025
Not available
Justice J.B. Pardiwala · Justice Manoj Misra

Background

Multiple FIRs were lodged at PS Kotwali, District Fatehpur (U.P.), alleging that persons connected with a university (SHUATS, Prayagraj) and a local church/mission hospital were carrying out mass religious conversions of Hindus to Christianity at the Evangelical Church of India, Hariharganj, on 14.04.2022, using inducements (cash, jobs, medical treatment, marriage proposals) and, in some FIRs, threats. Petitioner No. 1, the Vice-Chancellor of the university, and others named in these FIRs approached the High Court and then the Supreme Court under Article 32 seeking quashing of the FIRs, arguing that the complainants were not the persons allegedly converted (making them incompetent to lodge a complaint under the then-unamended Section 4 of the U.P. Conversion Act), that some FIRs were essentially duplicates of an already-registered FIR, and that the investigation and material gathered did not inspire confidence.

Decision Breakdown

The Supreme Court held that FIR No. 224/2022 was legally defective because it was lodged by a person (a Vishwa Hindu Parishad office-bearer acting as an informant/whistleblower) who was not a person competent to complain under the statutory scheme then in force, and quashed it along with all consequential proceedings. Two other FIRs (Nos. 55/2023 and 60/2023) were quashed as impermissible successive FIRs on the same facts, following the principle in the T.T. Antony case. FIR No. 54/2023 was quashed because the Court found the institution of the complaint and the quality of investigative material insufficient to inspire confidence in its bona fides. As for FIR No. 538/2023, the Court agreed the conversion-related charge could not survive but de-tagged and sent back for further hearing the separate allegations of firearm use and extortion, since the complete chargesheet/case diary was not before it. The batch of appeals and writ petitions was accordingly allowed in these terms, with one matter kept pending for further consideration.

Lesson Learnt

A criminal complaint about religious conversion cannot be validly lodged by someone who was not personally subjected to the alleged conversion (a mere informant/third party), and courts will not permit multiple, near-identical FIRs to be registered over the same incident: protections that guard citizens against misuse of the criminal process, even in sensitive matters involving religious conversion allegations.

Official source (sci.gov.in)View Judgment (PDF)

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