Supreme Court Quashes Multiple FIRs Under U.P. Conversion Act in Alleged Mass Conversion Case

Supreme Court Quashes Multiple FIRs Under U.P. Conversion Act in Alleged Mass Conversion Case

The petitions and appeals arose from several FIRs registered in Fatehpur, Uttar Pradesh, under the Indian Penal Code and the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021, alleging mass religious conversion of about 90 Hindus to Christianity on 14 April 2022 at the Evangelical Church of India. The first FIR was lodged by a VHP functionary; subsequent FIRs Nos. 54/2023, 55/2023 and 60/2023 were filed months later by individuals claiming to be victims of the same event. Separate FIR No. 47/2023 concerned an earlier alleged conversion on 25 December 2021. The High Court of Allahabad had refused to quash these FIRs, leading to the present batch before the Supreme Court.

The petitioners argued that the successive FIRs violated the principle laid down in T.T. Antony v. State of Kerala, (2001), as they arose from the same incident and amounted to abuse of process. They further contended that the first informant in FIR was not a “person competent” under unamended Section 4 of the U.P. Act, which restricts complaints to the aggrieved person or close relatives, rendering that FIR itself invalid. The State defended the investigations, submitting that all FIRs disclosed cognizable offences of conversion by allurement and fraud.

Issue Raised: Whether multiple FIRs could be maintained for the same alleged incident of conversion, and whether an FIR lodged by a person not competent under Section 4 of the U.P. Conversion Act is legally sustainable.

SC’s Judgment: The Supreme Court held that an FIR lodged by a third party not personally aggrieved was invalid under the unamended Section 4 of the Act, which expressly limits the right to complain to the victim or specified relatives. However, once that FIR was found incompetent, the subsequent FIRs by alleged victims could not be treated as “second FIRs” barred by T.T. Antony. After examining the investigation record, the Court observed that all subsequent FIRs contained almost identical allegations and arose from the same occurrence, thereby constituting parallel proceedings for one event. Allowing them to continue would amount to an abuse of process.

Therefore, the Court quashed all subsequent FIRs and proceedings arising therefrom, holding that only one competent complaint could survive per incident. It clarified that Section 4 of the U.P. Act must be construed strictly and cannot authorise third-party or organisation-based complaints. The Court further cautioned that law-enforcement agencies must avoid registering multiple FIRs for the same transaction and ensure adherence to procedural safeguards while enforcing the conversion law.

To Read Full Judgment, Download PDF Given Below