The Supreme Court of India on May 23, 2025, set aside two FIRs filed against Dr. Vinod Bihari Lal, the Vice-Chancellor of Sam Higginbottom University of Agriculture, Technology and Science (SHUATS), Prayagraj. These FIRs were registered under the Uttar Pradesh Gangsters and Anti-Social Activities (Prevention) Act, 1986.
A bench comprising Justice J.B. Pardiwala and Justice R. Mahadevan stated:
“We are convinced that the continuation of the Special Sessions trial no. 54/2019 arising out of FIR no. 850/2018 registered at Naini Police Station, district Allahabad, Uttar Pradesh is nothing but the abuse of the process of law.”
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The bench also quashed the non-bailable warrants issued against the Vice-Chancellor and set aside the Allahabad High Court’s order that had earlier refused to quash the proceedings.
The allegations against Dr. Lal included leading an “organised” gang of two individuals, involved in committing economic crimes like fraud and forgery. It was claimed that these acts fell under Chapters XVI, XVII, and XXII of the Indian Penal Code and were committed to gain personal and financial benefits. Additionally, the FIR alleged that the accused created a sense of fear among the public, which discouraged anyone from reporting them or testifying in court.
Justice J.J. Munir of the Allahabad High Court had earlier ruled that violence is not a required element for qualifying a group as a “gang” under Section 2(b) of the 1986 Act. He noted that even non-violent economic offences could be considered gang activities if they are carried out systematically by a group.
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However, the Supreme Court disagreed with this interpretation. It declared the FIRs and ongoing trial as misuse of the legal system. The top court further ruled:
“It is in this result that the appeals succeed and are hereby allowed. The impugned judgment and order dated 19 April 2023 rendered by the High Court at judicature Allahabad rejected the application under Section 482 CrPC referred by the Appellant for the quashing of the proceedings and rejection of the application preferred by the Appellant for quashing of non-bailable warrants in the order dated 28-2-2023 and 14-3-2023 are hereby set aside. Resultantly, the criminal proceedings arising from FIR 850/2018 dated 27-8-2018 registered as P.S. Naini District Allahabad, Uttar Pradesh, are hereby quashed.”
While pronouncing the judgment, Justice Pardiwala remarked:
“In this case, my law clerk Sakshi drew our attention that there are now guidelines issued by you pursuant to some order passed by the court. We have looked into and we want you to adhere to your guidelines.”
This ruling came after the Supreme Court had, on October 18, 2024, reserved judgment in a batch of petitions. These petitions were filed seeking quashing of criminal proceedings against Dr. Lal and other SHUATS officials in connection with allegations of mass religious conversions to Christianity.
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With this decision, the apex court has emphasized the importance of safeguarding individuals from wrongful prosecution and reinforced that legal provisions must not be misused to target individuals without substantial grounds.
Case Details: VINOD BIHARI LAL Versus THE STATE OF UTTAR PRADESH AND ANR., Crl.A. No. 000777 - 000778 / 2025 (and connected matters)
Appearance: Senior Advocate Siddharth Dave for Vinod Bihari and Additional Advocate General for Uttar Pradesh, Garima Prasad
