The Bombay High Court has quashed criminal proceedings against four Amravati residents accused of pressuring a Hindu couple to embrace Christianity, holding that insisting on religious conversion does not, by itself, constitute an offence of outraging the religious feelings of any class of citizens.
Justice M W Chandwani of the Nagpur Bench observed that the allegations against the accused, even if accepted, indicated that they were promoting their religion rather than deliberately insulting another religion or its beliefs.
In its October 6 order, the Court set aside the FIR and chargesheet against Joseph Khudawant, a senior citizen, his son Victor Khudawant, daughter-in-law Elvina Khudawant, and social worker Anant Mankar.
Allegations Against the Accused
The criminal case arose from a complaint alleging that the four individuals repeatedly pressured the complainant and his wife to convert from Hinduism to Christianity.
According to the prosecution, the accused offered financial assistance to the couple in exchange for conversion. They allegedly promised monthly payments to both spouses, financial support for their children’s education, and the construction of a house for the family.
Following the complaint, police in Amravati registered an FIR against the four individuals in January. They were accused of engaging in deliberate and malicious acts intended to outrage religious feelings and insulting the religion or religious beliefs of a class of citizens.
The accused subsequently approached the High Court seeking to quash both the FIR and the chargesheet filed against them.
Promoting Religion Not Equivalent to Insulting Religious Beliefs
Before the High Court, the accused maintained that they had neither insulted any religion nor acted with malicious intent to hurt the religious sentiments of any community.
Examining the allegations, Justice Chandwani found that the essential element of deliberate and malicious intent to outrage religious feelings was absent.
The Court distinguished between encouraging someone to adopt a particular religion and committing an act intended to insult the religious beliefs of a community.
It observed that the allegations, at their highest, suggested that the accused had insisted upon the complainant and his wife converting to Christianity. However, such conduct did not establish that they had outraged the religious feelings of any class of citizens.
The Court concluded that the accused were merely promoting their religion, which could not automatically be treated as an act intended to insult another religion.
Court Examines Law on Religious Conversion
The High Court also considered the legal position governing religious conversion in Maharashtra at the time of the alleged incident.
It noted that the alleged conduct occurred in 2025, when the state had no law prohibiting religious conversion through allurement.
The Court further recorded that Maharashtra subsequently enacted legislation concerning the protection of religious freedom and the prohibition of unlawful conversion from one religion to another, which came into force on August 28, 2026.
The timing of the alleged incident was therefore relevant to the Court’s examination of the criminal proceedings.
FIR and Chargesheet Quashed
Finding that the allegations did not establish the offence of deliberately and maliciously outraging religious feelings, the High Court allowed the applications filed by the four accused.
It accordingly quashed the FIR registered in Amravati and the chargesheet filed against Joseph Khudawant, Victor Khudawant, Elvina Khudawant and Anant Mankar.
