Allahabad High Court Grants Bail to Tamil Nadu Man Accused of Mass Illegal Conversions In UP

The Allahabad High Court recently granted bail to a Tamil Nadu resident and his co-accused, who have been in custody for nearly four months in a Mirzapur case registered under Uttar Pradesh’s anti-illegal religious conversion law.

The bench of Justice Ashutosh Srivastava allowed the bail application filed by Dev Sahayam Deniyal Raj and Paras in a 2025 case, registered at Ahraura police station under Sections 3 and 5(1) of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021.

The two accused were arrested on September 30, 2025, and had approached the high court under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking enlargement on bail.

According to the prosecution, Deniyal, a resident of Tamil Nadu, was operating in the Mirzapur region as part of an organised network allegedly involved in religious conversions. Police have claimed that the group had already facilitated the conversion of around 70 persons and was planning further conversions of 500 when the case was registered. The prosecution has also alleged that Deniyal functioned as a local coordinator for an organisation based outside Uttar Pradesh.

During the bail hearing, counsel for the accused argued that the applicants had been falsely implicated and had no criminal antecedents. It was submitted that no incriminating material was recovered from their possession during the course of investigation and that continued incarceration was unwarranted at the bail stage.

The counsel for the accused also questioned the manner in which the criminal proceedings were initiated, contending that the first information report was lodged by a person who was neither the alleged aggrieved individual nor a relative or immediate family member. Reliance was placed on the recent judgment of the Supreme Court in Rajendra Bihari Lal and Another vs. State of Uttar Pradesh and others (2025), interpreting the scope of who may initiate prosecution under the anti-conversion law. The high court, however, did not record any finding on this issue.

In the Rajendra Bihari Lal case, the apex court held that prosecution under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act can be initiated only by the aggrieved individual or, alternatively, by their immediate family members or blood relatives. Paragraph 117 of the judgment states that permitting strangers or unrelated third parties to set the criminal law in motion would intrude upon an individual’s freedom of conscience and religion.

The State opposed the present bail plea, citing the seriousness of the allegations and the scale at which the alleged activities were being carried out. The prosecution maintained that the accused were part of a coordinated effort involving multiple individuals.

After hearing both sides, the court observed that, considering the nature of the accusations, the severity of punishment in the event of conviction, the nature of the supporting evidence, and the overall facts and circumstances of the case, a case for bail was made out. Court clarified that it was not expressing any opinion on the merits of the prosecution’s case.

The high court directed that Dev Sahayam Deniyal Raj and Paras be released on bail upon furnishing a personal bond and two reliable sureties each in the like amount to the satisfaction of the court concerned.

Case Title: Dev Sahayam Deniyal Raj And Another vs. State of UP

Judgment Date: January 28, 2026

Bench: Justice Ashutosh Srivastava