Supreme Court Quashes FIR Under UP Anti-Conversion Law Against SHUATS Vice-Chancellor

A Landmark Reaffirmation of Liberty and Religious Freedom

In a significant reaffirmation of constitutional safeguards for individual liberty and religious freedom, the Supreme Court on October 17, 2025, quashed an FIR registered under the Uttar Pradesh Prohibition of Unlawful Religious Conversion Act, 2021 against Dr. Rajendra Bihari Lal, Vice-Chancellor of the Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS), Prayagraj.

The bench observed that the allegations—based solely on the statements of a disgruntled student and a former employee—did not establish any prima facie case of forced or unlawful conversion. Consequently, the Court held that continuation of proceedings would constitute an abuse of the process of law.

By setting aside the FIR, the Court has sent a clear message against overzealous or politically motivated use of anti-conversion statutes without adequate evidentiary foundation.

The Case and Its Core Allegations

The case arose from a 2023 FIR registered in Prayagraj under Sections 3 and 5 of the UP Anti-Conversion Act, alleging that Dr. Lal and others were “inducing” students to convert to Christianity through university activities. The complaint was lodged by a former student, who claimed he had been pressured to participate in “conversion events” on campus.

Dr. Lal, a senior academic and administrator, denied all allegations and approached the Supreme Court seeking to quash the FIR, arguing that:

• The accusations were vague, uncorroborated, and politically motivated.

• No conversion or attempt to convert had taken place.

• The complainant’s statements were not supported by any material evidence, witnesses, or documents.

The Court examined the case records and found no credible evidence or material to support the charge of conversion activity, nor any violation of the statutory requirements of the 2021 Act.

Why the Court Intervened: Abuse of Criminal Process

The bench noted that criminal law cannot be invoked on mere suspicion or political motive, particularly when fundamental rights such as freedom of religion and personal liberty are at stake.

In its reasoning, the Court reiterated established principles for quashing proceedings under Section 482 of the Code of Criminal Procedure (CrPC):

• Absence of prima facie material: The FIR must disclose basic facts constituting an offence; mere conjecture or hearsay is insufficient.

• Prevention of harassment: The judiciary must intervene to prevent unnecessary harassment of individuals through misuse of penal laws.

• Protection of constitutional rights: Laws restricting personal freedoms must be narrowly construed and cannot operate on vague or unverified allegations.

The Court’s order emphasized that “the extraordinary power of the State to prosecute under special laws must not become an instrument of persecution.”

Anti-Conversion Laws Under Judicial Scrutiny

The Uttar Pradesh Prohibition of Unlawful Religious Conversion Act, 2021—one of several such statutes enacted by states including Madhya Pradesh, Gujarat, and Uttarakhand—has faced repeated criticism for vague definitions of “allurement,” “coercion,” and “conversion.”

Under the Act:

• Any person seeking to convert must notify the District Magistrate in advance.

• Conversions through “misrepresentation, force, undue influence, coercion, or allurement” are punishable by imprisonment.

• The burden of proof often falls on the accused to demonstrate that the conversion was voluntary.

Legal scholars and civil rights advocates have argued that such provisions invert the presumption of innocence, exposing individuals to arbitrary prosecution. The Supreme Court’s latest order implicitly recognizes this risk by holding that allegations must be backed by concrete evidence before criminal proceedings can commence.

Context: The SHUATS Controversy

SHUATS, formerly known as Allahabad Agricultural Institute, has a long history of Christian missionary affiliation but functions as a state-recognized, secular university. The institution has been periodically accused of promoting religious activities, though no court has ever substantiated such claims.

In this case, the FIR was triggered by:

• A single complaint from a student who had been expelled for disciplinary reasons.

• Corroboration from a dismissed employee with pending grievances against the administration.

The Supreme Court noted these circumstances and remarked that the motives of complainants must be carefully scrutinized in cases invoking stringent criminal provisions. The Court concluded that “continuation of such proceedings, in the absence of any evidence, would amount to harassment.”

A Pattern of Judicial Protection for Religious Liberty

This judgment builds upon a growing line of Supreme Court and High Court decisions emphasizing restraint in applying anti-conversion laws:

• Stanislaus v. State of Madhya Pradesh (1977): The Court upheld states’ power to regulate conversion by force or fraud, but clarified that voluntary conversion is protected under Article 25 (freedom of conscience and religion).

• Pastor Anil Kumar v. State of Uttar Pradesh (Allahabad HC, 2022): The Court quashed similar FIRs where the police failed to demonstrate any evidence of coercion or inducement.

• Salim v. State of Uttarakhand (2024): The Supreme Court held that invoking anti-conversion statutes in matrimonial disputes without evidence constitutes misuse of law.

By reinforcing these precedents, the Court in Dr. Rajendra Bihari Lal v. State of Uttar Pradesh has reiterated that criminal prosecution cannot proceed on the basis of animosity, presumption, or religious bias.

Constitutional Underpinnings: Article 25 and Due Process

At the heart of this decision lies the balance between religious freedom and public order.Article 25 of the Constitution guarantees:

• The freedom to profess, practice, and propagate one’s religion;

• Subject to restrictions of public order, morality, and health.

However, the Supreme Court clarified that this restriction cannot justify pre-emptive criminalization of religious association or belief. Unless there is credible proof of coercion, inducement, or fraudulent activity, the invocation of anti-conversion provisions violates the due process guarantee under Article 21.

This aligns with the Court’s broader jurisprudence that liberty cannot be curtailed by vague suspicion. The order signals that criminal prosecution, especially under sensitive religious statutes, must meet a higher evidentiary threshold before it can proceed.

Why This Matters Beyond the Case

The implications of the judgment go far beyond the SHUATS controversy. By reinforcing evidentiary discipline in applying anti-conversion laws, the Court has:

• Reasserted judicial oversight over politically charged prosecutions.

• Protected institutional autonomy of minority-run educational establishments from harassment.

• Clarified the evidentiary threshold required before invoking special penal statutes that touch upon constitutional freedoms.

  
  

Conclusion

The Supreme Court’s quashing of the FIR against the SHUATS Vice-Chancellor reaffirms the judiciary’s role as a constitutional sentinel—ensuring that laws enacted for public order are not weaponized to target individuals or institutions without cause.

At a time when anti-conversion statutes are increasingly invoked across states, this decision serves as a vital reminder: faith cannot be policed by presumption, and criminal law cannot substitute proof with suspicion.