Supreme Court Quashes FIRs Against SHUATS University VC & Officials Under UP Religious Conversion Act
Gursimran Kaur Bakshi
17 Oct 2025 10:54 AM IST
The Supreme Court today(October 17) quashed the FIRs and the consequential criminal proceedings under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, against the Vice Chancellor and other officials of the Sam Higginbottom University of Agriculture Technology and Science (SHUATS), Prayagraj, over alleged forced mass religious conversions of people to Christianity.
The Special Leave Petitions under Article 136 were filed against an order of the Allahabad High Court refusing to quash FIRs lodged against the Vice-Chancellor (Dr.) Rajendra Bihari Lal, Director Vinod Bihari Lal and other officials of the institute. The parties have also filed writ petitions seeking to consolidate certain FIRs and challenging them.
Another is the set of writ petitions filed under Article 32 praying for the quashing of all FIRs and alternatively, transfer of all similar criminal complaints/FIRs filed across the State of Uttar Pradesh against the petitioners to Naini, Allahabad and then consolidating them all and for a stay of coercive action on them during the pendency of the present petition.
A bench comprising Justice J.B. Pardiwala and Justice Manoj Misra read out the conclusions as follows.
a. FIR 224/2022 registered in Kotwali Police Station in Fatehpur district, dated 15.02.2022 suffers from an incurable legal defect having been lodged by a person otherwise not competent to lodge it under law as per the UP Conversion Act, as it stood then. Hence, the FIR and all consequential proceedings are quashed.
b. FIR 55/2023 and FIR 60/2023, respectively lodged with the Kotwali Police Station, are quashed since they are squarely covered by TT Antony decision (which holds that multiple FIRs over the same offence are not maintainable). Any consequential proceedings emanating from the said two FIRs are also terminated.
c. A writ petition under Article 32 of the Constitution seeking the quashing of the FIR is maintainable as held in a catena of decisions of the Court. In the extraordinary facts and circumstances of this case, the writ petitions seeking the quashing of FIR 224/2022 and FIR 47/2023 are not only maintainable but also entertainable and are hereby allowed.
d. The institution of the complaint and the quality of the materials gathered by the investigating authorities into FIR 54/2023 fail to inspire any confidence as regards the bona fides of the investigation, making it a fit case to quash the FIRs. FIR 54/2023 and all consequential proceedings are hereby quashed.
g. High Court committed an error in declining to quash FIR 538/2023 to the extent no offence under the UP Conversion Act can be said to have made out, in view of the embargo contained in Section 4 of the Act. However, we clarify that in so far as alleged offences under Section 307, 386, 504 IPC are concerned, the matter requires further consideration. The writ petition is detagged for a separate hearing. The interim protection granted to the petitioners will continue till the matter is finally decided.
The FIRs [224/2022, 47, 54, 55 and 60 of 2023] are for offences punishable under Sections 153A, 506, 420, 467, 468, and 471 of the Indian Penal Code and Sections 3 and 5(1) of The Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021.
The Supreme Court had earlier granted interim protection from arrest to the Vice Chancellor and other officials of the SHUATS in December last year. It also stayed the arrest through in certain other cases.
During a hearing in May, last year, the Court had orally observed that some parts of the UP law on religious conversions seemed to be violative of Article 25 of the Constitution.
Arguments of the parties
The petitioners have argued that they belong to a religious minority and are continuously harassed and intimidated by the Uttar Pradesh Government. It was stated that there is no evidence in support of the arguments contended by the respondents that the petitioners have engaged in forced conversions.
The petitioners stated that the FIRs registered are false and frivolous and untenable in law and have been lodged to disrupt the functioning of the SHUATS. They have sought consolidation of all FIRs in this case, as according to them several FIRs have been registered in different parts of Uttar Pradesh. One set of FIRs pertains to the alleged mass conversion.
Another FIR was lodged in 2023, where individual persons have alleged that they were allured to convert to Christianity on the pretext of getting cash, a job in SHUATs or getting married, in which the petitioners are directly named. Similar other FIRs registered in 2023 pertain to individual conversions.
"These several F.I.R's are a part of well-coordinated and malicious campaign by the Respondent State to infringe the fundamental rights guaranteed under Articles 25, 29 and 30," as argued by the petitioners. The petitioners referred to Arnab Ranjan Gonswami v. UOI (2020) and argued that multiple FIRs and their investigation endangered and infringed their personal rights and liberty.
Further, they relied on Satinder Singh Bhasin v. Government (NCT of Delhi) & Ors (2019) and stated that the Supreme Court has held that in exercising Article 32 jurisdiction, 'bail can be granted if the multiple F.I.Rs originate from the same alleged incident'.
Considering the importance of the matter, the Attorney General for India R. Venkataramani, was asked to assist the Court relating to the issue of forceful and deceitful religious conversions. On the last hearing, the AGI submitted that the Court should adopt a 'broad view' in the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 adding a caveat that there cannot be "a prosecution which is unfair under the law and a person's liberty cannot be taken for granted".
He informed the Court that the present FIRs disclose the commission of a cognisable offence. The evidence, including Aadhaar card printing machines, has been recovered from the university's premises along with bogus Aadhaar cards. These were allegedly used for forceful conversion.
The AGI also referred to the provisions of the 2021 Act. As per Section 3 by "use of practice of misrepresentation, force, undue influence, coercion, allurement, or by any fraudulent means." Section 3 prohibits any person from abetting, or conspiring for such conversions. AGI argued that the contents of the FIR indicate that conversions are unlawful.
Next, he perused Section 4 which allows "any aggrieved person" including persons, brother, sister, or any other person related to blood, marriage or adoption may lodge an FIR on such conversions which contravened provisions of Section 3. On seeking clarification as to who were the aggrieved persons who were entitled to file FIR in the present case, the AGI stated that except for the FIR lodged in 2024, all are by aggrieved persons.
It should be noted that a challenge to the constitutionality of the 2021 Act is pending before the Supreme Court in cases filed by the Citizen for Justice and Peace and Jamiat Ulema-i-Hind.
Case Details: RAJENDRA BIHARI LAL AND ANR. v. STATE OF U.P. AND ORS.| W.P.(Crl.) No. 123/2023 and connected cases.
Senior Advocate Siddharth Dave appeared for the petitioners along with Advocate Pallavi Sharma, Attorney General for India R Venkataramani, and AAG Garima Prashad appeared for the State of UP.