In a landmark ruling delivered on 17 October 2025, the Supreme Court of India struck down several FIRs registered under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 (“UP Conversion Act”), holding that the complaints were filed by persons not legally competent to do so. The bench comprising Justice J.B. Pardiwala and Justice Manoj Misra observed that “the ends of justice would not be met by allowing proceedings that are fundamentally flawed to continue.”
The Court was hearing a batch of writ petitions and criminal appeals filed by Rajendra Bihari Lal and others, challenging multiple FIRs from Fatehpur district alleging unlawful religious conversions.
Background
The case stemmed from six FIRs registered between 2022 and 2023, invoking serious charges under the Indian Penal Code (IPC) and the UP Conversion Act. The petitioners contended that these FIRs were politically motivated, lodged by persons who were not “aggrieved” within the meaning of Section 4 of the Act, which limits who can file such complaints.
Under Section 4, only the converted individual, their family members, or close relatives by blood or marriage may initiate a complaint. In these cases, the FIRs were lodged by unrelated individuals, allegedly “acting on hearsay or general suspicion.”
The Allahabad High Court had earlier refused to quash the FIRs, prompting the petitioners to move the Supreme Court.
Court’s Observations
The Supreme Court examined the statutory competence of the complainants, the maintainability of multiple FIRs for the same offence, and the broader issue of whether a writ under Article 32 could be used to quash criminal proceedings.
Justice Pardiwala noted, “FIR No. 224/2022 suffers from an incurable defect-it was lodged by a person not competent in law to do so under the then prevailing statutory scheme.” He added that allowing such cases to proceed would amount to “a direct affront to procedural fairness.”
The Court also reaffirmed the principles from State of Haryana v. Bhajan Lal and Neeharika Infrastructure v. State of Maharashtra, clarifying that courts can intervene to prevent abuse of the criminal process, even at the investigation stage.
“The High Courts and this Court,” the bench stated, “must remain vigilant to ensure that criminal law is not used as a weapon of harassment or political retribution.”
Furthermore, the bench held that multiple FIRs based on the same set of allegations violate the “test of sameness” and are thus impermissible. The justices cited earlier rulings, including T.T. Antony v. State of Kerala, to emphasize that successive FIRs in the same transaction amount to “abuse of statutory power.”
Decision
After an exhaustive 157-page judgment, the Court concluded:
- FIR No. 224/2022, filed at Kotwali Police Station, Fatehpur, was quashed for being lodged by an incompetent complainant.
- FIR Nos. 55/2023 and 60/2023 were quashed as they violated the principle laid down in T.T. Antony.
- FIR Nos. 224/2022 and 47/2023 were quashed in entirety under Article 32, with all consequential proceedings terminated.
- FIR No. 54/2023 was also quashed for lack of bona fide investigation.
- Regarding FIR No. 538/2023, the Court found no offence under the Conversion Act but kept the issue of IPC offences (Sections 307, 386, 504) pending for further scrutiny.
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Concluding the judgment, the bench remarked, “The extraordinary power to quash proceedings is not to be exercised lightly, but where clear injustice stares the Court in the face, intervention becomes a duty.”
The appeals were allowed with no order as to costs, and the pending matter related to FIR No. 538/2023 was de-tagged for separate hearing.
Case: Rajendra Bihari Lal & Another v. State of Uttar Pradesh & Others (2025)
Citation: 2025 INSC 1249
Date of Judgment: 17 October 2025
