The Supreme Court has quashed multiple FIRs filed under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, against Dr. Rajendra Bihari Lal, Vice-Chancellor of Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS), and several other university officials. The bench, comprising Justices JB Pardiwala and Manoj Misra, held that the proceedings were based on completely incredulous material and amounted to an abuse of the criminal process. The judgment emphasized that neither religious gatherings nor charitable activities are offenses under the UP Conversion Act, and criminal law cannot be misused to harass innocent individuals.
The Court examined the procedural and factual aspects of the FIRs and found significant irregularities in the way investigations had been conducted. One of the FIRs was deemed legally barred because it had been lodged by a person who was not competent to file a complaint under the Act as it existed at that time. The other FIRs were found to be repetitive and mechanically produced, with witness statements being “cyclostyled” and containing errors, including incorrect names of the deponents. Upon closer scrutiny, the Court noted that these statements only described activities such as religious gatherings, Bible preaching, and charity work, with no evidence of unlawful religious conversion. The bench underscored that the UP Conversion Act and the Indian Penal Code do not criminalize religious gatherings or charitable initiatives, and filing criminal cases based on such activities constituted harassment and an abuse of legal process.
The Supreme Court expressed concern over the misuse of criminal law to target individuals without credible evidence. It observed that law enforcement agencies and prosecuting authorities should not act arbitrarily based on incredulous material to initiate prosecution against innocent persons. The judgment reinforced the principle that the criminal justice system exists to protect rights and maintain justice, not to enable harassment or intimidation through frivolous or baseless legal actions. By quashing the FIRs, the Court emphasized that fundamental rights, including the right to practice religion and engage in charitable work, must be protected from arbitrary interference.
While the Court quashed the FIRs under the UP Conversion Act, it allowed certain proceedings under the Indian Penal Code to continue. Sections such as 307 (attempt to murder), 386 (extortion), and 504 (intentional insult) were permitted to proceed for further consideration, and the accused were granted interim protection from arrest, which will continue during the pendency of these proceedings. The Court’s decision carefully distinguished between frivolous or baseless accusations and genuine criminal allegations under the IPC, ensuring that the latter could be adjudicated appropriately without subjecting the accused to unnecessary harassment under unrelated laws.
This ruling demonstrates the judiciary’s role in safeguarding individual liberties and preventing the misuse of statutory provisions. It clarifies that laws like the UP Conversion Act must be applied in accordance with their intent and cannot be manipulated to target individuals for lawful religious or charitable activities. The judgment reinforces the principle that prosecuting authorities must exercise caution and ensure credible evidence before initiating criminal proceedings, thereby upholding the rule of law and protecting citizens from arbitrary legal action. By quashing the FIRs against the SHUATS officials, the Supreme Court sent a clear message that innocent individuals cannot be subjected to harassment under the guise of preventive or regulatory statutes, and that the courts will intervene to prevent misuse of the criminal process.
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