'Mechanical FIRs Under Anti-Conversion Law Will Not Do': Allahabad High Court Warns State

The Allahabad High Court recently quashed a first information report registered under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, after the State itself conceded that the case could not be sustained.

The order was passed by a bench of Justices Abdul Moin and Babita Rani, allowing a writ petition filed by Sabir Ali and setting aside an FIR dated April 26, 2025, registered at Jethwara police station in Pratapgarh district under Sections 5(1), 8(2) and 8(6) of the 2021 Act.

The FIR had been lodged by a Sub-Inspector of Police, who alleged that the petitioner had unlawfully converted certain individuals to another religion. The petitioner approached the high court seeking quashing of the criminal proceedings, contending that the allegations were false and unsupported by facts.

When the matter first came up for consideration on November 20, 2025, the court took note of submissions made not only by the petitioner but also by counsel appearing for the private respondents, who were shown as the alleged victims in the FIR. The private respondents categorically stated in a short counter affidavit that no religious conversion had taken place and that they continued to follow their own religion, customs and traditions by free choice.

Court recorded that the private respondents denied any inducement, coercion, pressure or allurement, and asserted that the FIR was “absolutely false, concocted and baseless". Taking note of these submissions, the bench observed that the FIR appeared to be prima facie false.

In a strong order passed on November 20, the court directed the Principal Secretary (Home), Government of Uttar Pradesh, to file a personal affidavit explaining why such an FIR had been registered by a police officer under a stringent special law. The bench also raised the issue of imposing exemplary costs on the State if it was found that frivolous FIRs were being lodged without due application of mind.

Court emphasised that false prosecutions under the anti-conversion law not only force citizens to unnecessarily approach the high court but also result in wastage of precious judicial time. Until the next date of hearing, court granted protection to the petitioner by directing that no coercive action be taken pursuant to the FIR.

When the case was taken up again on December 2, 2025, the personal affidavit of the Principal Secretary (Home) had already been filed. However, before the court could examine the contents of that affidavit, the Government Advocate made a statement on behalf of the State that the FIR itself could be quashed.

Accepting the submission made by the State, the bench allowed the writ petition and formally quashed the FIR dated April 26, 2025. Court recorded that, in view of the State’s stand, the continuation of the criminal proceedings would serve no purpose.

While granting relief to the petitioner, the high court issued a note of caution to the State authorities. It observed that the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act is a special law with stringent provisions, and therefore greater care and responsibility must be exercised while registering FIRs under it.

Court specifically cautioned against the practice of registering FIRs in a “mimeographic style” without proper verification of facts or application of mind, warning that such actions could invite serious consequences in future cases.

With these observations, the FIR was quashed and the writ petition was disposed of, with consequences to follow as per law.

Case Title: Sabir Ali vs. State Of U.P. Thru. Prin. Secy. Home, Lko. And Others

Order Date: December 2, 2025

Bench; Justices Abdul Moin and Babita Rani