The Madras High Court has upheld the cancellation of American citizen John Daniel’s Overseas Citizen of India (OCI) registration over allegations of conducting missionary activities in India without prior official permission. Justice D. Bharatha Chakravarthy dismissed his petition, holding that permission was necessary even if religious preaching did not result in conversions.
Background
Daniel received OCI registration in February 2015. He challenged the September 4, 2026, cancellation order, maintaining that he visited India primarily to meet his elderly mother and relatives. He denied engaging in missionary activities or promoting religious conversions.
The authorities relied on posters, online material and advertisements relating to religious meetings in Tamil Nadu and Andhra Pradesh between 2017 and 2019. They alleged that Daniel had conducted religious gatherings without the required permission under the Central Government’s March 4, 2021 notification.
Justice Chakravarthy examined the material produced by the authorities and rejected Daniel’s contention that his visits were exclusively for family purposes. The Court explained that the permission requirement extended beyond activities resulting in religious conversions.
The judgment stated:
"If the petitioner preaches and undertakes activities to spread the word of ‘God’, such activities would fall within the meaning of missionary activity."
The Court also considered Daniel’s argument that the cancellation violated the principles of natural justice, which require a fair opportunity to respond to allegations. It distinguished the circumstances of his case, noting the extensive material presented by the authorities and his categorical denial of missionary activities.
The Court observed:
"It is not only for conversion, but even to be a missionary preaching his religion, it is only a prior permission that is mandated."
Finding no ground to interfere with the cancellation order, the High Court dismissed the writ petition. It clarified that Daniel could apply for a regular visa to visit his mother and undertake religious meetings in India after obtaining the requisite official permission.
The Court made no order as to costs.
Case Details
- Case Title: John Daniel v. Union of India and Others
- Case Number: W.P. No. 37464 of 2026
- Judge: Justice D. Bharatha Chakravarthy
- Decision Date: October 26, 2026
