Contours of FIR Quashing Redefined-Supreme Court on Abuse of Process & Article 32 Powers-Supreme Court Clarifies the Law on Religious Conversion Cases

Rajendra Bihari Lal & Anr. v. State of Uttar Pradesh & Ors.
2025 INSC 1249 | Decided on: 17 October 2025 | Bench: J.B. Pardiwala, J.

Headnote

The Supreme Court re-affirmed that the inherent power to quash criminal proceedings exists to prevent abuse of process and secure justice — even after filing of charge-sheet or under Article 32 — but multiple FIRs on the same incident and FIRs lodged by incompetent complainants are impermissible.

Ratio & Principles Settled

1. Multiple FIRs for the same incident are barred.
2. Inherent powers under Section 482 CrPC / Article 226 can be exercised even after a charge-sheet to prevent miscarriage of justice.
3. Supreme Court under Article 32 may directly quash an FIR if a fundamental right is violated.
4. Only an “Aggrieved Person” as defined in Section 4 of the U.P. Conversion Act can lodge an FIR — third-party complaints are void ab initio.
5. Freedom of faith and choice is part of Article 21-the State cannot police personal conscience.
6. FIRs founded on malafides or with political motives are liable to be quashed.

Factual Matrix

Several FIRs were filed in Uttar Pradesh against the Vice-Chancellor of SHUATS University and others under the U.P. Prohibition of Unlawful Conversion of Religion Act, 2021, alleging mass religious conversions. The Petitioners sought Quashing of these FIRs—Some filed by political or social activists, others by alleged victims—Arguing that multiple FIRs on the same incident and those by Unauthorised Persons were Illegal. The Allahabad High Court refused relief, leading to a batch of Appeals and Writs before the Supreme Court.

The Verdict

• The Supreme Court Quashed FIR No. 224/2022 for being filed by an incompetent complainant ( Not Being the aggrieved).
• Subsequent FIRs Nos. 54, 55 & 60/2023 were quashed as repetitive and barred.
• FIR No. 47/2023 (pertaining to a different incident) was also quashed for inordinate delay and lack of material.
• The Court clarified that filing of a charge-sheet does not curtail the High Court’s power to quash proceedings.
• The Supreme Court, invoking Article 32, exercised its own jurisdiction to prevent abuse of process.

Impact Analysis

This judgment marks a significant recalibration of criminal process jurisprudence:

• It re-asserts safeguards against misuse of criminal law for political or ideological vendettas.
• By limiting who may lodge FIRs, it narrows the scope for public-interest-style criminal complaints.
• It fortifies the principle of “sameness” — reinforcing T.T. Antony as a bulwark against investigative overreach.
• The Court’s recognition of Article 21 autonomy underlines a liberal reading of personal liberty amid social-religious prosecutions.
• It re-establishes that judicial conscience, not procedural rigidity, is the ultimate test in quashing matters.

Author:
Abhijit Banerjee, Advocate-on-Record & Arguing Counsel, Supreme Court of India. Criminal & Constitutional Jurisprudence

Disclaimer:
This blog is for academic purposes only and to facilitate quick reading of the ruling and its legal principles.

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