Supreme Court Quashes FIRs Against SHUATS Officials in Alleged Forced Conversion Case

Agencies, Delhi, October 27, 2025 : The Supreme Court recently quashed criminal proceedings against the Vice Chancellor and other officials of the Sam Higginbottom University of Agriculture Technology and Science (SHUATS), Prayagraj, in connection with allegations of forced mass religious conversion. The petitions were filed by Vice Chancellor Rajendra Bihari Lal, Director Vinod Bihari Lal, and other officials, who were accused of involvement in illegal religious conversion activities under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021.

Key Points of the Case:

1. Background of the Allegations:
   The case stemmed from an FIR filed in November 2023, which alleged that a lower-middle-class woman had been lured into converting to Christianity through gifts, clothing, and promises of job security. The accused were also said to have pressured the woman into bringing other women for conversion. Additionally, the victim claimed she was subjected to regular sexual exploitation.

2. Allegations of Foreign Funding:
   Uttar Pradesh Police had raised concerns about foreign funding, stating that SHUATS had received over ₹34 crore through its Foreign Contribution (Regulation) Act (FCRA) account, allegedly for the purpose of illegal conversion activities. This funding reportedly came from several countries, including the United States, Afghanistan, Japan, Germany, and many others.

3. Initial Ruling by Allahabad High Court:
   The Allahabad High Court had initially directed the Vice Chancellor and other officials of SHUATS to surrender before the court by December 20, 2023. The court also condemned the alleged religious conversion activities, labeling them as unpardonable, particularly the manipulation of vulnerable individuals, including the young woman in question, for conversion.

   In its ruling, the High Court described the act of convincing a young girl to be baptized in exchange for gifts and promises of better opportunities as an "unpardonable sin." The High Court also found that the victim had been influenced by a higher priest to convert for the promise of job security.

4. Supreme Court's Intervention:
   In December 2023, a vacation bench of the Supreme Court stayed the Allahabad High Court's order for surrender. The matter was brought before the top court after the SHUATS officials challenged the proceedings. The Supreme Court took into account the complexity of the case, the allegations of coercion and sexual exploitation, and the involvement of foreign funding.

   The Attorney General for India, during the hearing, had informed the bench that there were no unfair prosecutions under the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021. This was in response to concerns raised by Justice JB Pardiwala about whether the FIRs were being filed by "aggrieved persons" as required under Section 4 of the U.P. Conversion Act.

5. Supreme Court's Ruling:
   The Supreme Court eventually quashed the criminal proceedings against the Vice Chancellor and other officials of SHUATS. The court ruled that the continuation of the criminal proceedings would amount to an abuse of the judicial process. It also expressed concerns about the manner in which the FIRs were lodged and the credibility of the allegations.

   The court's intervention emphasized that even though the allegations were serious, the prosecution under the U.P. Conversion Act could not proceed under the specific circumstances of this case, especially in light of the procedural irregularities and doubts about the authenticity of some of the allegations.

Court's Observations and Legal Implications:

• On the U.P. Conversion Act: The Court did not delve into the constitutional validity of the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021 but raised concerns regarding its application in this case, particularly with respect to the process for filing FIRs and the competence of parties filing complaints.

• On the Issue of Foreign Funding: While the UP police had highlighted the receipt of foreign funds, the Court did not make a final judgment on the matter, suggesting that further investigation might be required. The allegations of funding for conversion purposes remain contentious but were not directly addressed in the Court’s ruling.

• On Privacy and Freedom of Religion: The Court took a measured approach, balancing the right to religious freedom with the need to prevent coercion, allurement, or fraudulent conversions. The case also raised issues of privacy and autonomy, particularly regarding the voluntariness of conversion.

Impact of the Ruling:

• Relief for SHUATS Officials: The ruling came as a significant relief to the Vice Chancellor and other officials of SHUATS, as it quashed the ongoing criminal proceedings against them, which had been initiated under the U.P. Conversion Act.

• Precedent on Forced Conversions and State Interference: The case reinforces the need for careful scrutiny of allegations involving forced conversions, the role of state authorities in religious matters, and the potential abuse of legal provisions. The Court emphasized that criminal law cannot be used as a tool of harassment and that accusations must be substantiated by credible evidence.

Conclusion:

This ruling by the Supreme Court reflects its cautious approach to the application of the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021, particularly in cases where serious allegations of coercion and exploitation are made. While the Court quashed the FIRs and criminal proceedings against the SHUATS officials, it left room for further investigation into the allegations, particularly regarding the funding sources. The case raises important questions about the balance between religious freedom, the right to privacy, and the state’s role in regulating religious conversions.

For further details, the case is reported under Rajendra Bihari Lal v. State of Uttar Pradesh (WRIT PETITION (CRL.) NO. 123 OF 2023).