Allahabad High Court Cautions State Authorities Against Lodging 'Mimeographic Style' FIRs Under Stringent UP Anti-Conversion Act
Sparsh Upadhyay
16 Dec 2025 8:14 AM IST
The Allahabad High Court (Lucknow Bench) has cautioned the Uttar Pradesh State authorities against registering mechanical and routine cases under the stringent Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021.
The Court observed that, given the 'stringent' provisions of the special Act, the authorities must exercise greater care and avoid registering FIRs in a "mimeographic style".
The observation was made by a Division Bench of Justice Abdul Moin and Justice Babita Rani while quashing a 'false' FIR lodged by a police officer in the Pratapgarh district against one Sabir Ali.
In its order, the Court took specific note of the manner in which the FIR was registered and the mechanical approach adopted by the police in the case.
In a strong observation, the High Court remarked thus:
"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".
Case in brief
Briefly put, an FIR was registered on April 26, 2025, under Sections 5(1), 8(2), and 8(6) of the Act, 2021, against the petitioner. The informant, a Sub-Inspector, alleged that the petitioner was involved in unlawful religious conversion.
However, the case took a different turn when the alleged victims (Respondents No. 5 to 8) appeared before the High Court and filed a short counter affidavit in which they categorically stated that the allegations in the FIR were "absolutely false, concocted, baseless and without any substance".
They submitted that no incident of inducement, allurement or coercion had taken place and that they were following their religion "as per their own free will".
Taking note of the same, in its earlier detailed order [dated November 20, 2025], the Court expressed strong displeasure over the facts of the case. It also made a prima facie observation that the FIR lodged by the State officer appeared "patently false".
The Bench observed that it was 'deluged' with such matters and questioned why citizens should be constrained to approach the Court, spending money and time, for cases that "could have been nipped in the bud by the State itself".
To address this, the Court had directed the Principal Secretary (Home), Lucknow, to file a personal affidavit explaining why exemplary cost should not be imposed against the State.
When the matter was taken up on December 2, the Principal Secretary (Home) filed the affidavit. However, the government advocate submitted that the Court may quash the FIR.
Accepting this statement, the Bench allowed the petition and quashed the FIR. However, it cautioned the authorities against lodging mechanical FIRs under the stringent 2021 Act.
Counsel for Petitioner(s) : Akhand Kumar Pandey, Abhishek Singh
Case title - Sabir Ali vs. State Of U.P. Thru. Prin. Secy. Home, Lko. And Others
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