Legal Review and Analysis of Rajendra Bihari Lal & Anr vs State of Uttar Pradesh & Ors 2025 INSC 1249

1. Heading of the Judgment

Case Title: Rajendra Bihari Lal & Anr. vs. State of Uttar Pradesh & Ors.
Citation: 2025 INSC 1249
Court: Supreme Court of India
Bench: Justice J.B. Pardiwala

2. Related Laws and Sections

The judgment extensively deals with the following statutes and provisions:

• The Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 (U.P. Conversion Act):
  Section 3: Prohibits conversion through misrepresentation, force, undue influence, coercion, allurement, or by any fraudulent means.
  Section 4 (Unamended): Specified the categories of persons competent to lodge an FIR for contravention of the Act (any aggrieved person, their parents, siblings, or blood/marriage/adoption relatives).
  Section 5: Prescribes punishment for contravention of Section 3.
  Sections 8 & 9: Lay down the onerous procedure for pre-and post-conversion declarations.

• The Indian Penal Code, 1860 (IPC): Sections 153-A (promoting enmity), 420 (cheating), 467 & 468 (forgery), 471 (using forged document as genuine), 506 (criminal intimidation), 120-B (criminal conspiracy), 307 (attempt to murder), and 386 (extortion).

• The Code of Criminal Procedure, 1973 (CrPC):
  Section 154: Registration of First Information Report (FIR).
  Section 161: Examination of witnesses by police.
  Section 482: Inherent powers of the High Court to quash proceedings to prevent abuse of process or secure ends of justice.

• The Constitution of India:
  Article 32: Power of the Supreme Court to issue writs for enforcement of fundamental rights.
  Article 25: Freedom of conscience and free profession, practice, and propagation of religion.
  Article 21: Right to life and personal liberty, encompassing the right to privacy and dignity.

3. Basic Judgment Details

This was a batch of matters, including three Writ Petitions under Article 32 of the Constitution and nine Criminal Appeals, challenging the validity of six distinct FIRs registered in Uttar Pradesh. The FIRs alleged mass religious conversion and other associated offences under the IPC and the U.P. Conversion Act. The petitioners, including the Vice-Chancellor of a university and others, sought the quashing of these FIRs, alleging they were frivolous, vexatious, and a gross abuse of the process of law. The High Court of Allahabad had previously refused to quash most of these FIRs, leading to the appeals before the Supreme Court.

4. Core Principles and Analysis of the Judgment

The Supreme Court's judgment is a profound analysis of the limits of state power in regulating religious freedom and the procedural safeguards against the misuse of criminal law. The core of the judgment can be broken down into the following key issues and the Court's reasoning.

A. The Primacy of the Special Law: Validity of FIR No. 224/2022

The Issue: Whether an FIR under the U.P. Conversion Act can be registered by a person not specified in the unamended Section 4 of the Act.

The Analysis and Finding: The Court conducted a meticulous analysis of the unamended Section 4, which explicitly stated that only an "aggrieved person" or their close relatives could lodge an FIR for unlawful conversion. The complainant in the first FIR (No. 224/2022) was a functionary of the Vishwa Hindu Parishad, a third party with no personal or proximate connection to the alleged converts.

The Court rejected the State's argument that Section 154 of the CrPC, which allows any person to report a cognizable offence, should override this specific provision. Relying on its precedent in Union of India v. Ashok Kumar Sharma, the Court held that the U.P. Conversion Act is a special law that creates a distinct procedural regime. The legislature's intent was to restrict the locus standi to initiate prosecution, recognizing that religious belief is an intensely personal matter. Allowing third parties to complain would open the floodgates to frivolous and motivated litigation, leading to a grave intrusion into the individual's autonomy and privacy under Articles 21 and 25. Consequently, the Court held that FIR No. 224/2022, being lodged by an incompetent person, suffered from an "incurable legal defect" and was liable to be quashed.

B. The Prohibition of Multiple FIRs: Validity of FIR Nos. 54, 55, and 60 of 2023

The Issue: Whether multiple FIRs can be registered concerning the same incident of alleged mass conversion.

The Analysis and Finding: The Court applied the well-settled "test of sameness" from its judgments in T.T. Antony v. State of Kerala and Babubhai v. State of Gujarat. It noted that FIR Nos. 54, 55, and 60 of 2023 all pertained to the exact same alleged incident of mass conversion on 14.04.2022 at the Evangelical Church in Fatehpur. Except for the names of the complainants, the allegations, the date, the place, and the penal sections invoked were virtually identical and appeared to be "cyclostyled" copies of each other.

The Court strongly deprecated this practice, holding that the scheme of the CrPC recognizes only the "first information" about a cognizable offence as the FIR. Any subsequent information about the same incident or connected offences must be treated as statements under Section 161 CrPC and investigated as part of the same case. Registering multiple FIRs for the same cause of action amounts to an abuse of the investigative process and subjects the accused to unwarranted harassment. The Court found that these subsequent FIRs were a mala fide attempt to overcome the illegality of the initial FIR (No. 224/2022) by presenting persons who, after a considerable delay, masqueraded as "victims." Therefore, these subsequent FIRs were also quashed.

C. The Scrutiny of Evidence and Abuse of Process

The Issue: Whether the materials collected during investigation justified the continuation of criminal proceedings.

The Analysis and Finding: The Court went beyond a mere prima facie examination of the FIRs and delved deep into the chargesheets and case diaries. It uncovered shocking irregularities that pointed to a non-genuine and motivated investigation:

• Cyclostyled Affidavits and Statements: Affidavits and Section 161 statements of different witnesses were found to be identical, word-for-word, except for the names, indicating they were drafted from a common prototype.

• Glaring Discrepancies: In one affidavit, the deponent Sanjay Singh erroneously referred to his own name being changed from "Rajesh Kumar Dwivedi," exposing the lack of authenticity.

• Incredible Witness Testimonies: The Court found that the complainants in the subsequent FIRs had, in their initial statements recorded during the investigation of FIR No. 224/2022, stated that they were not victims but were part of the group that had raided the church. Their subsequent U-turn to claim victimhood after nine months was deemed not credible.

• Lack of Incriminating Material: The forensic reports of seized materials, including videos of religious sermons, did not reveal any direct allurement for conversion. The Court noted that organizing religious gatherings or charitable work, even with foreign funds, is not ipso facto a crime.

Relying on Mohammad Wajid v. State of U.P., the Court held that in cases of apparent abuse of process, it has a duty to "read between the lines." It concluded that the entire investigative process was not aimed at uncovering the truth but at somehow substantiating baseless allegations, making it a classic case for quashing to secure the ends of justice.

D. The Expansive Scope of Article 32 Jurisdiction

The Issue: Whether the Supreme Court can directly quash FIRs under Article 32 of the Constitution.

The Analysis and Finding: The State argued that the petitioners should have first approached the High Court. The Court affirmed that while approaching the High Court is a matter of orderly procedure, the existence of an alternative remedy does not bar the Supreme Court's jurisdiction under Article 32, which is itself a fundamental right. Citing precedents like Amitbhai Anilchandra Shah and Vinod Dua, the Court held that in cases of glaring violation of fundamental rights (like liberty, privacy, and freedom of religion), it is not only empowered but duty-bound to intervene directly. The Court found the present case, involving a systematic abuse of process and infringement of constitutional rights, to be a fit case for exercising its extraordinary writ jurisdiction.

5. Final Outcome of the Judgment

The Supreme Court allowed all the petitions and appeals. It quashed the following FIRs and all consequential legal proceedings emanating from them:

• FIR No. 224 of 2022

• FIR No. 47 of 2023

• FIR No. 54 of 2023

• FIR No. 55 of 2023

• FIR No. 60 of 2023

• FIR No. 538 of 2023

The Court held that the continuation of proceedings in these cases would result in a travesty of justice and a gross abuse of the process of law.

6. MCQs Based on the Judgment

1. According to the Supreme Court's judgment in Rajendra Bihari Lal v. State of U.P., what was the primary legal defect in FIR No. 224/2022?
A) It was registered after an inordinate delay.
B) It was investigated by an officer without territorial jurisdiction.
C) It was lodged by a person not authorized under the unamended Section 4 of the U.P. Conversion Act.
D) It did not disclose the commission of a cognizable offence.

C) It was lodged by a person not authorized under the unamended Section 4 of the U.P. Conversion Act.

2. The Supreme Court quashed the subsequent FIRs (Nos. 54, 55, and 60 of 2023) primarily based on the legal principle that?
A) The offences alleged were non-cognizable.
B) The investigation had already been completed in the first FIR.
C) There cannot be multiple FIRs for the same incident or occurrence, as per the "test of sameness."
D) The complainants in these FIRs were not Indian citizens.

C) There cannot be multiple FIRs for the same incident or occurrence, as per the "test of sameness."