Allahabad HC Says Bible Distribution, Preaching Isn’t a Crime; Slams UP Police for Overstepping

Allahabad, Dec 9, 2025: In a strongly worded order, the Allahabad High Court recently stated that simply handing out the Bible or preaching a faith does not amount to an offence under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021. The Bench of Justice Abdul Moin and Justice Babita Rani also criticised the Uttar Pradesh Police for what it described as "bending backward" to arrest the accused immediately after the FIR was filed, even though no victim had come forward at that stage to support allegations of forced conversion.

These remarks came while the Court was hearing a plea by the accused seeking to quash the FIR registered against them under the 2021 Act. The FIR, lodged by one Manoj Kumar Singh, claimed that the petitioners had conducted a prayer meeting with the intention of converting Dalits and economically weaker individuals. According to the complainant, when he reached the residence of the petitioners-accused, he saw an LED screen in the verandah where they were "preaching the tenets of Christianity" and distributing Bibles.

During the hearing of the quashing petition, the Court cited Section 3 of the 2021 Act, which prohibits conversion through misrepresentation, force, undue influence or allurement. The Bench emphasized that the essential requirement for invoking this provision is the presence of a specific ‘person’ alleging that an attempt is being made to convert them. It further pointed out that when the FIR was filed on August 17, 2025, no such victim had appeared, and the FIR only recorded the recovery of an LED screen and Bibles.

"From perusal of the FIR it does not emerge that at the time of lodging of the FIR... any person had come forward indicating that he had been converted to any other religion," the Bench noted. The Court also highlighted that although one alleged victim, in his initial statement on September 4, said nothing about conversion, he later stated on October 25—nearly two months after the FIR—that he had been offered allurement to change his religion.

The Bench further commented that since the 2021 Act is a special law, authorities ought to have considered the fact that on the date of the incident (August 17), there was no material suggesting that any offence under the Act had occurred. Pointing to this discrepancy, the Court said: "Thus, it is prima facie apparent that the authorities have bent themselves backward in order to arrest the petitioner(s) even though it is not known as to how the complainant had got information about any offence... These are all strange facts which need to be explained," the Court remarked.

The Bench also referred to the Supreme Court’s recent ruling in Rajendra Bihari Lal vs. State of U.P., 2025 LiveLaw (SC) 1021, and reaffirmed that because the 2021 Act is a "special Act," authorities must follow its provisions strictly rather than rely on assumptions. The Court further scrutinized the complainant’s role and issued him notice, asking him to clarify in a counter affidavit his authority to enter the petitioners’ house. The Court raised several questions: How did he obtain information about the supposed offence? How was he able to gather a crowd to accompany him to the accused’s home? If he "barges into the house of a third person", what crime had the petitioners committed by trying to stop him? The Bench also questioned how charges under Section 352 (intentional insult to provoke breach of peace) and Section 351(3) (criminal intimidation) of the BNS could be applied to the petitioners when they may have been protecting their own property from intrusion.

The case will be taken up again after four weeks.

Courtesy: Verdictum