New Delhi: In a groundbreaking decision that reinforces the foundational principles of India’s Constitution, the Supreme Court has affirmed that the freedom to choose and practice one’s religion is deeply intertwined with the right to personal privacy, placing such matters firmly outside unwarranted government intervention. This ruling, delivered on October 17, 2025, in the case of Rajendra Bihari Lal vs. State of Uttar Pradesh and Others, has far-reaching implications for how anti-conversion laws are applied across the country. By quashing multiple First Information Reports (FIRs) filed under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, the court highlighted the need to protect individual autonomy while preventing the misuse of legal mechanisms for harassment.
The judgment, authored by a Division Bench consisting of Justices J.B. Pardiwala and Manoj Misra, underscores that religious beliefs and choices form part of a person’s private sphere, immune to arbitrary state control. This perspective draws from the broader constitutional framework, emphasizing that privacy is not just a standalone right but permeates various fundamental freedoms, including those under Article 25.
Background of the Case: Allegations of Mass Conversions and Legal Challenges
The case originated from a series of FIRs lodged in Fatehpur district, Uttar Pradesh, accusing officials from the Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS), including its Vice-Chancellor Rajendra Bihari Lal, of orchestrating unlawful mass religious conversions from Hinduism to Christianity. The primary FIR, registered on April 15, 2022, at Kotwali police station, stemmed from a complaint by Himanshu Dixit, a leader of the Vishwa Hindu Parishad (VHP). It alleged that around 90 individuals were coerced into converting during a gathering at the Evangelical Church of India in Hariharganj on Maundy Thursday, a significant Christian observance.
The complaint invoked sections of the Indian Penal Code (IPC) such as 307 (attempt to murder), 504 (intentional insult to provoke breach of peace), 386 (extortion), alongside Sections 3 and 5(1) of the UP anti-conversion law, claiming the use of undue influence, fraud, coercion, and promises of financial incentives. Subsequent FIRs, filed between December 2021 and January 2023, echoed similar accusations, targeting largely the same group of individuals, including Rajendra Bihari Lal and Director Vinod Bihari Lal.
Petitioners approached the Supreme Court under Article 32, seeking to quash these FIRs, arguing they were baseless, delayed, and constituted an abuse of process. The court examined each FIR meticulously, identifying procedural flaws, lack of credible evidence, and inconsistencies in witness statements. Notably, no alleged victims of conversion came forward as complainants; instead, the FIRs were initiated by third parties with potential vested interests.
In its 158-page verdict, the Bench criticized the repeated registration of FIRs for the same incident as an “abuse of investigative powers,” leading to unwarranted harassment. The court remarked that such actions undermine the fairness of the legal process and expose accused persons to repeated scrutiny without justification.
Interconnection Between Freedom of Religion and Right to Privacy
At the heart of the ruling is the court’s elucidation of how Article 25 – which guarantees the freedom of conscience and the right to freely profess, practice, and propagate religion – inherently includes dimensions of privacy. The Bench described this connection as intrinsic, viewing privacy as a safeguard against state interference in personal beliefs.
Drawing from the landmark nine-judge decision in Justice K.S. Puttaswamy (Retd.) v. Union of India (2017), the court reiterated that while privacy is not explicitly listed as a fundamental right in Part III of the Constitution, it infuses various provisions, including Article 25. The judgment states that the broader scheme of fundamental rights portrays multiple aspects of privacy, with Article 25 embodying the right to hold and express – or not express – religious convictions privately.
The court emphasized that freedom of conscience under Article 25 operates within a “zone of purely private thought process,” making it immune to external dictation. Privacy, in this context, serves as a prerequisite for the meaningful exercise of religious freedom, extending to related rights under Articles 26 (freedom to manage religious affairs) and 28 (freedom from religious instruction in certain educational institutions).
A key observation was that mandating the public declaration or publication of one’s faith could violate privacy rights under Articles 21 and 25. The Bench noted that such requirements in anti-conversion laws must pass the “privacy test,” questioning whether provisions demanding advance notifications and police inquiries for conversions infringe on individual decisional autonomy.
Furthermore, the court drew parallels between choices in religion and marriage, both rooted in personal autonomy. Citing precedents like Shafin Jahan v. Asokan K.M. (2018), it affirmed that the right to select a faith or a life partner is integral to Article 21’s guarantee of life and liberty. The intimacies of personal relationships, including decisions on whom or whether to marry, fall within privacy’s ambit and “transcend the control of the State.”
The ruling prohibits the state from regulating or limiting such choices, asserting that individual autonomy reigns supreme in matters of faith, belief, and conscience. The court observed that the Constitution’s assurance of the right to practice, profess, and propagate religion cannot be curtailed by laws that overstep into private domains.
Concerns Over Anti-Conversion Laws and Secularism
The decision casts a critical eye on the UP Prohibition of Unlawful Conversion of Religion Act, 2021, highlighting its potentially onerous conditions. Provisions requiring 60-day prior declarations for conversions, mandatory police inquiries, and public exhibition of converts’ details were flagged as possible infringements on privacy and religious freedom. The court suggested these might need further scrutiny to align with constitutional standards, particularly in a secular nation.
Reminding that India is a secular country, the Bench reiterated that the term “secular” in the Preamble forms part of the Constitution’s basic structure, as established in Kesavananda Bharati v. State of Kerala (1973). Article 25 grants everyone the right to freely profess, practice, and propagate any religion, subject only to reasonable restrictions for public order, morality, and health.
The court cautioned against allowing strangers or unrelated parties to initiate criminal proceedings under the Act, as this could dilute personal liberty and open doors to frivolous litigation. Section 4 of the Act limits complaints to aggrieved persons or their close relatives, a restriction the Bench upheld to prevent misuse.
In quashing the FIRs, the court stressed that criminal law cannot serve as a “tool of harassment.” It pointed out investigative lapses, such as delayed complaints and absence of direct victims, labeling the prosecutions as based on “incredulous material” that would result in a “travesty of justice” if continued.
Broader Implications and Future Scrutiny
This pronouncement revives hopes among minority communities and legal experts that anti-conversion laws in various states – currently under Supreme Court examination – will be evaluated through the lens of privacy and autonomy. Experts suggest the ruling could prompt a relook at pending cases, encouraging stricter scrutiny of FIRs to curb persecution under the guise of preventing coercive conversions.
The decision aligns with earlier judgments upholding individual choices in faith and marriage, reinforcing that state intervention must not encroach on private spheres. By detagging certain pleas for fresh adjudication and extending interim protections, the court ensured balanced proceedings while affirming its role as the ultimate enforcer of fundamental rights under Article 32.
In essence, the Supreme Court’s linkage of religious freedom and privacy as interwoven rights beyond state control marks a pivotal moment in Indian jurisprudence. It not only quashes baseless FIRs but also sets a precedent for protecting personal beliefs from overzealous regulation, upholding the secular ethos that defines the nation. As challenges to similar laws in states like Gujarat persist, this ruling could shape the discourse on balancing religious protections with individual liberties, ensuring that laws meant to prevent coercion do not themselves become instruments of intrusion.
FAQs
What was the key finding of the Supreme Court in the case of Rajendra Bihari Lal vs. State of Uttar Pradesh and Others?
The Supreme Court ruled on October 17, 2025, that the right to freedom of religion under Article 25 of the Indian Constitution is intrinsically linked to the right to privacy, forming a protected sphere free from state interference. The court emphasized that privacy encompasses the freedom of conscience and the choice to express or not express one’s religious beliefs, quashing multiple FIRs filed under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, for lacking credible evidence and constituting an abuse of legal process.
How does the Supreme Court connect the right to privacy with freedom of religion?
The court clarified that Article 25, which guarantees the freedom to profess, practice, and propagate religion, includes elements of privacy by protecting an individual’s internal beliefs and choices. Drawing from the Justice K.S. Puttaswamy (Retd.) v. Union of India (2017) judgment, the Bench noted that privacy, though not explicitly a fundamental right, pervades Part III of the Constitution, including Articles 25, 26, and 28. Privacy acts as a prerequisite for exercising religious freedom without state dictation.
What concerns did the Supreme Court raise about anti-conversion laws?
The court flagged provisions of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, such as mandatory 60-day prior declarations, police inquiries, and public disclosure of conversion details, as potential violations of privacy and religious freedom. It suggested these requirements must pass a constitutional “privacy test” and cautioned against third-party complaints by unrelated individuals, which could lead to harassment and frivolous litigation.
How does this ruling compare religious freedom to marital choice?
The Supreme Court drew an analogy between choosing one’s religion and selecting a life partner, stating both are expressions of individual autonomy under Article 21 (right to life and liberty). Referencing cases like Shafin Jahan v. Asokan K.M. (2018), the court held that decisions about faith or marriage fall within the private domain, beyond state control, ensuring individuals can freely make such choices without external regulation.
What are the broader implications of this judgment for India’s anti-conversion laws?
The ruling sets a precedent for scrutinizing anti-conversion laws across states, emphasizing the need to balance protections against coercive conversions with safeguarding individual autonomy and privacy. By quashing baseless FIRs and highlighting investigative misuse, the court signaled that such laws must align with constitutional guarantees of secularism and personal liberty, potentially influencing ongoing challenges to similar legislation in states like Gujarat.
