Madhya Pradesh High Court Refuses To Quash FIR Against Principal Accused Of Pressuring Hindu Teacher To Convert To Christianity

The Madhya Pradesh High Court recently refused to quash a criminal case filed under the Madhya Pradesh Freedom of Religion Act, 2021, against a school principal accused of pressuring a teacher to convert her religion. The court observed that the allegations in the First Information Report and the material collected during investigation were sufficient at this stage to proceed with trial and that inherent powers under Section 482 of the Code of Criminal Procedure must be exercised sparingly.

Justice Vinay Saraf passed the order while hearing a petition filed by Sister Bhagya, who sought quashing of FIR No. 36/2021 registered at Police Station Khajurao in Chhatarpur district under Sections 3 and 5 of the 2021 Act. The complaint was lodged by Ruby Singh, a teacher who had been working at Sacred Heart Convent High School Khajurao, where the petitioner served as principal.

According to the complaint, Singh alleged that she was repeatedly pressured and induced by the petitioner to convert from Hinduism to Christianity. She further alleged that when she refused to convert, she was harassed and ultimately removed from service.

Counsel for the petitioner, Advocate Abhishek Dilraj, argued that the case was malicious and stemmed from a service dispute. He submitted that Singh had been employed at the school since June 2016 with a salary of Rs. 5000 per month, but her performance was unsatisfactory and her services were terminated on July 17, 2020.

He contended that after her termination, the complainant allegedly began threatening the school authorities and later lodged a false complaint accusing the petitioner of forced religious conversion. The petitioner also relied on the Supreme Court’s ruling in State of Haryana v. Bhajan Lal, which recognises that criminal proceedings can be quashed where they are manifestly attended with mala fide intent.

Opposing the plea, Panel Lawyer Papiya Ghosh appearing for the State argued that the FIR and the charge sheet disclosed sufficient material to proceed against the accused.

After examining the record, the High Court noted that the complainant had specifically alleged that she was pressured to change her religion and was terminated when she refused. The Court observed that such allegations, if taken at face value, prima facie disclose offences under Sections 3 and 5 of the Madhya Pradesh Freedom of Religion Act, 2021.

The court further noted that the complainant’s statement had also been recorded under Section 164 CrPC before a magistrate, where she reiterated the allegations against the petitioner. Referring to established Supreme Court precedents, the judge emphasised that the power to quash criminal proceedings must be exercised cautiously and only in exceptional circumstances.

Quoting the principles laid down by the Supreme Court in Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, the High court reiterated that courts should ordinarily refrain from interfering with investigations into cognizable offences at an early stage. It observed, “Quashing of a complaint or FIR should be an exception and a rarity rather than an ordinary rule.”

The court also rejected the argument that the FIR was motivated solely by a service dispute. It observed that merely because there was an employment disagreement, the allegations of religious coercion could not be dismissed outright at the stage of considering a quashing petition.

“In view of the allegations made in the FIR and the material collected during investigation, it is not a fit case for quashment of the FIR and criminal proceedings,” the court held. It added that the petitioner would have the opportunity to establish her innocence during trial.

The court concluded that the allegations were serious and supported by statements collected during investigation. At this stage, it said, the court could not conduct a detailed examination of the evidence or assess its reliability. Consequently, the petition seeking quashing of the FIR was dismissed and the criminal case will now proceed before the competent trial court in accordance with law.

Case Title: Sister Bhagya v. The State of Madhya Pradesh and Others

Date of Order: March 9, 2026

Bench: Justice Vinay Saraf