‘Distributing, Preaching Bible Not a Crime’: Allahabad HC Questions FIR in Illegal-Conversion Case

The Allahabad High Court recently raised serious concerns over the manner in which an FIR was registered and arrests were made in a case under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, observing that there was no allegation of conversion from any individual at the time the FIR was lodged.

The bench of Justice Abdul Moin and Justice Babita Rani directed the complainant to explain how he obtained information about the alleged conversion activities and on what basis he mobilised people to enter the petitioners’ residence.

Court was hearing a petition filed by Ram Kewal Bharti @ Bablu and others seeking quashing of an FIR dated 17 August 2025. The FIR invoked Sections 3 and 5(1) of the 2021 Act and Sections 351(3) and 352 of the Bharatiya Nyaya Sanhita, 2023. The petitioners argued that the allegations were fabricated and unsupported by any victim statement indicating forced or fraudulent conversion.

According to the FIR, complainant Manoj Kumar Singh claimed he had received information that the petitioners were conducting a prayer meeting, distributing Bibles to Dalits and poor women and children, and attempting to convert them. He stated that upon reaching the spot with others, he found an LED installed and Christian preaching in progress.

Court, however, noted that the FIR contained no statement from any person claiming to have been converted or subjected to coercion, allurement or misrepresentation, which are the factors that form the core ingredients of an offence under Section 3 of the 2021 Act. Instead, the only allegations mentioned were distribution of Bibles and religious preaching.

The bench held that neither distribution of the Bible nor preaching of a religion constitutes a criminal offence under the statute. It emphasised that the “sine-qua-non” for invoking the anti-conversion law is a complaint by a person alleging actual conversion or an attempt through prohibited means, which was absent on the date of FIR registration.

Significantly, court recorded that the petitioners were arrested on the same day the FIR was lodged, despite there being no supporting statements from any alleged victims.

Statements alleging allurement to convert emerged only two months later, on 25 October 2025, when the police recorded the supplementary statement of one Ram Dev. His initial statement, dated 4 September 2025, had made no mention of conversion attempts. The statement of his wife, also supporting allegations of conversion, was recorded on the same day.

Court described these circumstances as “strange facts” requiring explanation, noting that authorities appeared to have acted precipitously despite the absence of material supporting invocation of the special statute at the initial stage. It also questioned how the complainant came to know of the alleged religious activity and how he mobilised a group to accompany him to the petitioners’ home.

Issuing notice to the complainant, the bench directed him to file a counter-affidavit clarifying the source of his information, the identity of persons he brought along, and how offences under Sections 351(3) and 352 of the BNS, which deal with criminal intimidation and provocation of breach of peace, could be made out when he barged into the petitioners’ residence. Court also directed him to disclose his criminal history, if any.

Court granted the State four weeks to file its counter-affidavit, after which the petitioners may file their reply within two weeks.

Court posted the matter to be listed afresh after expiry of the stipulated time.

Case Title: Ram Kewal Bharti @ Bablu And Others vs. State of UP and Others

Order Date: November 28, 2025

Bench: Justice Abdul Moin and Justice Babita Rani