The Allahabad High Court (Lucknow Bench) has quashed an FIR registered under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, after finding the allegations to be prima facie false. The Division Bench, comprising Justice Abdul Moin and Justice Babita Rani, heard Sri Abhishek Singh and Sri Akhand Kumar Pandey for the petitioner, Dr. V.K. Singh (Government Advocate) assisted by Sri Anurag Verma (AGA) for the State, and Sri Anuj Kumar Gupta along with Sri Alok Pandey for the private respondents. The Court issued a stern note of caution to State authorities, emphasizing that due to the stringent provisions of the special Act, they must exercise greater care and avoid registering FIRs in a “mimeographic style.”
The writ petition challenged an FIR lodged by a Sub-Inspector in Pratapgarh district, alleging unlawful religious conversion by the petitioner, Sabir Ali. The Court noted that the alleged victims themselves had filed affidavits denying any conversion or coercion. Following a previous order where the Court summoned the Principal Secretary (Home) to explain why exemplary costs should not be imposed for lodging a “patently false” FIR, the State Government conceded the matter. Consequently, the Court quashed the FIR and warned authorities to be more cautious in the future.
Background
The case arose from an First Information Report (FIR) dated April 26, 2025, registered as Case Crime No. 0081 of 2025 at Police Station Jethwara, District Pratapgarh. The FIR invoked Sections 5 (1), 8 (2), and 8 (6) of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021.
The informant in the case was Sri Hemant Yadav, a Sub-Inspector (Respondent No. 4). The allegations in the FIR suggested that the petitioner, Sabir Ali, had committed an offence under the Act of 2021 by converting private respondents to another religion.
The petitioner, Sabir Ali, approached the High Court seeking the quashing of the FIR, contending that the allegations were baseless and that the FIR was lodged by a police officer without any substance.
Arguments of the Parties
Petitioner’s Submissions: Represented by learned counsel Sri Abhishek Singh, the petitioner argued that the FIR lodged by the Sub-Inspector was “patently false.” The counsel submitted that no incident of religious conversion had taken place and that the petitioner had been falsely implicated.
Private Respondents’ Stance: The alleged victims (Respondents No. 5 to 8) were represented by learned counsel Sri Anuj Kumar Gupta and Sri Alok Pandey. A short counter affidavit was filed on their behalf, categorically stating that the allegations in the FIR were “absolutely false, concocted, baseless and without any substance.”
The affidavit clarified that:
“No incident of religious conversion, inducement, allurement, pressure or coercion has ever taken place with the petitioner or with any of the other alleged victims.”
It was further submitted that the private respondents have been following their own religion, social customs, and traditions “as per their own free will, independently and without interference or pressure from any corner.” They asserted that they had never adopted any other religion nor considered such a step.
Court’s Observations and Analysis
The Court referred extensively to its previous detailed order dated November 20, 2025, wherein it had expressed serious displeasure over the filing of the FIR.
In that order, the Bench observed that the FIR lodged by an officer of the State appeared to be “prima facie patently false” given the sworn statements of the alleged victims. The Court noted that aggrieved persons are “constrained to approach this Court for the redressal of their grievances whereby spending their valuable money and time,” while “precious judicial time of the Court is also wasted in dealing with such cases which could have been nipped in the bud by the State itself.”
Taking a serious view of the matter, the Court had previously directed the Principal Secretary (Home), Lucknow to file a personal affidavit explaining why the FIR was lodged by a State officer despite the allegations being prima facie false. The Court had also asked the Principal Secretary to indicate “why exemplary cost should not be imposed against the authorities who have not applied their mind while lodging the First Information Reports under the Act, 2021.”
During the final hearing on December 2, 2025, the Court noted that while the personal affidavit of the Principal Secretary (Home) had been filed, the State counsel, Dr. V.K. Singh, learned Government Advocate, stated that the FIR itself may be quashed by the Court, rendering the consideration of the affidavit’s averments unnecessary.
The Court allowed the writ petition based on this concession but issued a significant directive regarding the application of the Anti-Conversion law.
“However, considering the detailed order of this Court dated 20.11.2025 a note of caution is issued to the State authorities that being the special Act and having it’s stringent provisions the authorities should have to be more cautious in future while registering the FIRs in mimeographic style under the provisions of the Act, 2021.”
Decision
In view of the consensus at the bar and the statement made by the learned Government Advocate, the High Court allowed the writ petition.
The Court ordered:
“The FIR impugned dated 26.04.2025… is quashed.”
The Court had also previously directed that the private respondents “shall not be harassed in any manner by the respondents-authorities.”
Case Details
- Case Title: Sabir Ali Vs. State Of U.P. Thru. Prin. Secy. Home, Lko. And Others
- Case Number: Criminal Misc. Writ Petition No. 11000 of 2025
- Coram: Justice Abdul Moin and Justice Babita Rani
- Counsel for Petitioner: Sri Abhishek Singh, Sri Akhand Kumar Pandey
- Counsel for Respondents: Dr. V.K. Singh (Government Advocate), Sri Anurag Verma (AGA), Sri Anuj Kumar Gupta, Sri Alok Pandey
- Citation: 2025:AHC-LKO:79698-DB
