SUPREME COURT QUASHES CASES AGAINST SHUATS VC, CLARIFIES RELIGIOUS GATHERINGS AND CHARITY NOT OFFENCES UNDER UP CONVERSION LAW:

The Supreme Court of India has quashed multiple First Information Reports (FIRs) registered in Uttar Pradesh against Dr. Rajendra Bihari Lal, Vice-Chancellor of Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS), and several other officials of the institution. The Court held that the cases, filed under the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021, were founded on “completely incredulous material” and constituted an abuse of the criminal justice process. The bench comprising Justice J.B. Pardiwala and Justice Manoj Misra observed that the evidence collected during the investigation lacked credibility and fell short of the standard necessary to sustain a criminal prosecution.

The proceedings originated from several FIRs registered in different police stations of Uttar Pradesh alleging incidents of mass religious conversions. The first FIR, filed at the Kotwali Police Station, Fatehpur, in April 2022, accused the SHUATS officials of converting 90 individuals to Christianity during a Maundy Thursday event at the Evangelical Church of India. The complainant, however, was a third party—a member of the Vishwa Hindu Parishad—and not a victim, which rendered the FIR legally unsustainable under Section 4 of the U.P. Act. At that time, the statute permitted only a victim, their spouse, or relatives to lodge such a complaint. Rejecting the argument of the Attorney General that the general provisions of the Criminal Procedure Code should prevail, the Court clarified that the special law would take precedence and that the bar on third-party complaints served as a safeguard against frivolous and vexatious allegations.

The Court further found that several subsequent FIRs contained repetitive and mechanically reproduced allegations. Witness statements were found to be “cyclostyled,” with identical errors and even names being repeated across different depositions. For instance, two witnesses claimed that their names were changed from “Rajesh Kumar Dwivedi” to “Rajesh Kumar Samson,” suggesting clear fabrication. The materials produced by the investigating agencies, including videos and other evidence, only reflected religious gatherings and Bible readings, without any indication of coercive or fraudulent conversion. The bench underscored that neither the U.P. Conversion Act nor the Indian Penal Code criminalizes religious assemblies, preaching, or charitable activities carried out in the name of religion. It further noted that there was no evidence of irregular funding from international sources and that even if such irregularities had existed, other legal provisions could have been invoked instead of misusing criminal law.

The Supreme Court expressed concern that the investigation appeared designed not to ascertain the truth but to validate predetermined allegations. It observed that the pattern of filing multiple FIRs with overlapping content suggested an attempt to circumvent legal infirmities in earlier complaints. The bench stated that criminal law cannot be used as a means of harassment, allowing agencies to prosecute individuals arbitrarily on the basis of unreliable or manipulated evidence.

The Court quashed FIR Nos. 224/2022, 54/2023, 55/2023, and 60/2023, noting that they all arose from the same alleged incident and were subject to the principle laid down in the *T.T. Antony* case, which bars multiple FIRs for the same offence. It also found that FIR 54/2023, filed nearly nine months after the alleged incident, was an attempt to rectify procedural defects in the earlier FIR. The complainant’s contradictory statements across different FIRs further undermined the credibility of the case.

As for FIR No. 538/2023, which contained allegations of threats, extortion, and firing in addition to illegal conversion, the Court ruled that the charges under the U.P. Conversion Act were unsustainable since they were not made by an alleged victim. However, the remaining allegations were kept open for further consideration. Concluding that the materials on record reflected an attempt to misuse criminal proceedings, the Supreme Court quashed all FIRs related to alleged illegal conversions, reaffirming that religious gatherings or charity activities do not constitute offences under the U.P. Conversion Act.