Religious gatherings or charity work in name of religion not illegal under U.P. Conversion Act: Supreme Court

The Supreme Court has observed that the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 (the U.P. Conversion Act) does not state organization of religious gatherings or doing charity work in the name of religion is not a criminal offence.

"We do not find from a reading of the U.P. Conversion Act that organization of religious gatherings or doing charity work in the name of religion has also been made a criminal offence. No provision in the IPC prohibits such activities too", the Supreme Court observed as it quashed the criminal proceedings initiated against the Vice Chancellor and other officials of the Sam Higginbottom University of Agriculture Technology and Science (SHUATS), Prayagraj, in relation to alleged forced mass religious conversion.

A bench of Justices JB Pardiwala and Manoj Misra further observed that receiving foreign aid and carrying out charitable work, even in the name of religion, ipso facto is not a punishable offence under any of the legislations. 

"We are fully conscious that when offences are made out from a prima facie reading of the FIR the courts must exercise restraint in interfering with the continuation of criminal proceedings. However, we have not only gone through the FIR but also the materials gathered during the course of investigation. The hands of the Court cannot be said to be tied where on overall view of the matter, it appears that continuation of criminal  proceedings would result in a travesty of justice, even when the materials gathered may satisfy the ingredients necessary to constitute the offence", the court has further said.

Court further noted the entire process of investigation was not an attempt to uncover the truth of the allegations, but rather to find ways to somehow substantiate the allegations levelled in the FIR. 

Petitions were filed before the Supreme Court by Vice Chancellor Rajendra Bihari Lal, Director Vinod Bihari Lal and other officials of the Sam Higginbottom University of Agriculture Technology and Science (SHUATS), accused in an illegal mass religious conversion case.

In December 2023, a vacation bench of the Supreme Court of India had stayed the Allahabad High Court's order directing the Vice Chancellor and other officials of the Sam Higginbottom University of Agriculture Technology and Science (SHUATS) to surrender before the court by December 20, 2023.

The FIR, filed in November 2023, alleged that the victim, a lower-middle-class woman, was lured into Christianity through gifts and clothing, with the accused, including the SHUATS VC, allegedly pressuring her to bring other women for conversion and illegal activities. The victim claimed she was also subjected to regular sexual exploitation.

The high court had noted that the victim, influenced by a higher priest, was manipulated into adopting Christianity for the promise of job security. Despite arguments by the accused that the victim fabricated the story in retaliation for her job termination in 2022, the court found the allegations serious and horrifying. Considering the gravity of the charges and the ongoing investigation, the court refused to interfere and ordered the Superintendent of Police, Hamirpur to supervise the investigation by three senior police officers.

"No God or true Church or Temple or Mosque would approve such type of malpractices. If someone on his own, have chosen to get him converted to different religion is totally another aspect of the issue. In the instant case prevailing upon a tender mind of a young girl providing gifts, clothing and other physical amenities and then asked her to get her baptised is an unpardonable sin," the high court had ruled.

Case Details: RAJENDRA BIHARI LAL AND ANR. v. STATE OF U.P. AND ORS

Judgment Date: October 17, 2025

Bench: Justices Pardiwala and Misra