The Allahabad High Court, Lucknow Bench, issued a caution to the Uttar Pradesh state authorities against the registration of mechanical, routine, or formulaic first information reports under the stringent provisions of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021. The court’s observations were made by a Division Bench consisting of Justice Abdul Moin and Justice Babita Rani during the hearing of a petition challenging an FIR registered in Pratapgarh district. The High Court expressed concern that, given the Act’s stringent nature, law enforcement agencies must exercise greater diligence and care when registering FIRs and avoid doing so in a “mimeographic style,” meaning a repetitive and unthinking replication of allegations without proper consideration of the facts of each case. The bench observed that this caution was necessary because the special law’s provisions could have serious consequences for individuals named in complaints, and a mechanical approach to litigation could lead to grave injustice.
The case before the court involved an FIR lodged on April 26, 2025, under Sections 5(1), 8(2), and 8(6) of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, in which a sub-inspector alleged that the petitioner, Sabir Ali, was involved in unlawful religious conversion activities. On scrutiny by the High Court, however, it emerged that the factual basis for the FIR was seriously flawed. The alleged victims of the purported conversion, who were cited as Respondents Nos. 5 to 8, appeared before the court and filed counter affidavits stating categorically that the allegations leveled in the FIR were “absolutely false, concocted, baseless and without any substance.” They affirmed that no incident of inducement, allurement, coercion, or other impermissible influence had taken place and that they were following their religion of choice freely and voluntarily.
The High Court had earlier passed a detailed order on November 20, 2025, expressing strong displeasure over the facts of the case and making a prima facie observation that the FIR appeared “patently false” on its face. The bench noted that it had been deluged with multiple such matters and questioned why citizens should be compelled to approach the court, incurring time and expense, for cases that could have been prevented at the outset by the state authorities if they had applied proper scrutiny and judicial mind. In addressing these concerns, the High Court had directed the Principal Secretary (Home), Uttar Pradesh, to file a personal affidavit explaining why exemplary costs should not be imposed on the state for failing to prevent the filing of a frivolous FIR.
When the matter was taken up again on December 2, the Principal Secretary filed the required affidavit, and the government’s counsel submitted that the court may quash the impugned FIR. Accepting this position, the High Court allowed the petition and quashed the FIR against Sabir Ali. In its order, the bench reiterated its caution to the authorities, emphasizing that due to the Act’s stringent provisions, law enforcement must proceed with caution and ensure that complaints triggering criminal proceedings are grounded in material facts rather than being routine replications of previously filed FIRs. The court’s order underscored the need for careful and conscientious investigation before resorting to the severe penal consequences provided under the special anti-conversion law to prevent misuse and protect individuals from arbitrary or unfounded criminal proceedings.
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