‘No coercion plaint initially in FIR.’ Allahabad HC flags ‘strange facts’ in Sultanpur ‘conversion’

Bench says that the claims of allurement surfaced months later after FIR was filed, raising doubts about the basis for invoking Uttar Pradesh’s 2021 anti-conversion law.

The Allahabad HC noted that no person came forward on the date of the FIR to say they were converted, coerced, or even approached with an allurement | ANI File

New Delhi: The Allahabad High Court has flagged “strange facts” in the police version of events in a religious conversion case from Uttar Pradesh’s Sultanpur, noting that the authorities arrested five people on the day of the FIR even though no person claimed coercion, allurement or conversion at that time.

The High Court said this “alleged forced or induced conversion” of a “person” was a key ingredient of the offence of conversion under the state’s 2021 conversion law, which bans conversion in certain cases.

The court was hearing a petition by Ram Kewal Bharti and four others seeking the quashing of an FIR filed in August under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 and the Bharatiya Nyaya Sanhita, 2023 (BNS).

The FIR accused them of distributing Bibles, organising a prayer meeting for Dalits and poor families, and attempting to convert attendees to Christianity. The complainant, Manoj Kumar Singh, claimed he reached the petitioners’ home and saw an LED screen with Christian preaching.

The FIR was filed based on Sections 3 and 5 (1) of the 2021 Act. Section 3 prohibits the conversion of religions by undue influence such as misrepresentation and force, while Section 5 provides the punishment for contravention of the provision.

Police also invoked Sections 351 (3) and 352 of the BNS, which deal with criminal intimidation by threatening to cause death or grievous hurt and intentional insult with intent to provoke breach of peace, offences distinct from the special act.

The division bench of Justices Abdul Moin and Babita Rani noted that no person came forward on the date of the FIR to say they were converted, coerced, or even approached with an allurement. The FIR spoke only of Bibles being distributed and an LED playing Christian sermons.

The court said that the distribution of the Bible and the preaching of a religion were not a crime and the state counsel “failed to indicate” otherwise. It was required that a “person” alleged conversion by force, coercion, or allurement.

Without such an allegation, the “sine qua non” (essential condition) for imposition of Section 3 of the 2021 Act was missing.

To support the claim, the state had relied on a supplementary statement recorded more than two months later, in October 2025, where a person, identified as Ram Dev, suddenly claimed he was offered an allurement to convert.

However, Ram Dev’s initial statement did not mention this allurement. His wife’s statement alleging pressure to convert was also recorded only in October. The bench noted this sharp change in narrative and treated it as a red flag.

The delay, coupled with the shift in versions, raised doubts about whether the ingredients of the offence existed at all at the time of registration.

The bench noted that the petitioners were arrested the same day and questioned the arrest because no victim statement existed at the time to show any offence under the 2021 Act.

“Thus, it is prima facie apparent that the authorities have bent themselves backward in order to arrest the petitioner(s) even though it is not known as to how the complainant had got information about any offence as alleged in the FIR having come to his knowledge,” the court noted.

“These are all strange facts which need to be explained by the authorities more particularly when it is the life and liberty of the petitioner(s) which is involved.”

Counter-affidavit sought

The HC relied on the Supreme Court’s October ruling, which treated the 2021 Act as a “special” law requiring strict compliance. Special acts are laws relating to a particular subject, such as conversion and apply to a limited set of offences.

Relying on the apex court’s decision, the HC said that strict adherence to the provisions was required. “In case the FIR is being lodged under the provisions of the Act, 2021 obviously the authorities would have to strictly adhere to its provisions.”

In this case, the ingredients of the offence, including allegations of conversions, evidence of force or coercion, were not met. The court said that the authorities should have “applied their mind” before registration of the FIR under this special law.

The bench directed the complainant to file a counter-affidavit explaining how he received information about the alleged incident, how he gathered the people who accompanied him, why he attempted to enter the petitioners’ home, and his criminal history, if any.

The state has four weeks to file its response, after which the matter will be taken up by the court.

Akshat Jain is a final-year student at the National Law University, Delhi and is a contributor with ThePrint

(Edited by Sugita Katyal)