MP High Court Refuses To Quash FIR Against Three Accused Of Providing Equipment Used For Advertising Religious Conversion

The Madhya Pradesh High Court refused to quash an FIR against three men under the MP Freedom of Religion Act, observing that the investigation prima facie disclosed their involvement as they provided equipment used for advertising the alleged inducement for religious conversion. [2026 LiveLaw (MP) 248]It was alleged in the complaint that certain persons were inducing the villagers to convert their religion to Christianity by assuring them that those persons who follow Christianity would be provided free medical treatment, good education and a sum of Rs.50,000 each. The division bench of Justice Vijay Kumar Shukla and Justice Alok Awasthi observed:"The material collected during the course of investigation also prima facie discloses the involvement of the revision petitioners, Rai Singh as they are alleged to have provided the equipments used for advertising the alleged inducement for religious conversion. At the stage of framing of charge, the Court is only required to ascertain whether a prima facie case is made out and not to appreciate the evidence as if conducting a trial. Applying the said settled principle, sufficient material exists to proceed against the revision petitioners". Per the facts of the case, a written complaint was filed on June 20, 2025, by Gajraj Singh claiming that at 9 am, a meeting was convened at the house of Bhaggu Jiaji. The complaint alleged that certain persons in the village had induced the villagers to convert to Christianity on the assurance that Christian followers would be provided free medical treatment, good education, and a sum of ₹50,000 to each follower. Based on this complaint, a crime was registered against five persons, Manju, Kiran, Jagram, M, S and Mithun. During the investigation, it was discovered that the accused M and S were below the age of 18 years. The Trial Court thereafter framed charges against the revision petitioners Jagram, Manju Singh and Kiran on the ground that the complaint was not filed per section 4 of the Act, which governs who is legally permitted to file a complaint. Referring to scope of Article 227 CrPC, the court noted, "the judge concerned has to consider only the record of the case and the document produced along with the same. If on such consideration, the Court formed an opinion that there is no sufficient ground to proceed against the accused concerned, he shall be discharged after recording the reasons therefor. It is also evident from the precedence on the aforesaid question that while exercising the said power, the Court could sift the materials produced along with the final report only for the purpose of considering the question whether there is ground to proceed against the accused concerned". Referring to the State of Rajasthan v Ashok Kumar Kashyap, the court reiterated that it cannot conduct a mini-trial while deciding whether to frame charges or discharge an accused. Further, relying on the case of CBI v Aryan Singh, it was observed that the only question to be examined is whether sufficient material exists to proceed against the accused; courts are not expected to conduct a detailed appreciation of the evidence as would be done during a trial. In the present case, the bench noted that the complainant himself was present at the meeting where the alleged inducement to convert took place. Thus, the court rejected the contention that the complaint was not maintainable under Section 4 of the Act.Examining the allegations, the court held that the available evidence prima facie disclosed "allurement" within the meaning of Section 2(a) of the Act. Therefore, the court dismissed the revision petition and upheld the order framing charges. Case Title: Jagram v State of Madhya Pradesh, CRR-555-2026Citation: 2026 LiveLaw (MP) 248For Petitioners: Advocate Lokesh MehtaFor State: Government Advocate Jai Gopal ChouskeyClick here to read/download the Order

MP High Court Refuses To Quash FIR Against Three Accused Of Providing Equipment Used For Advertising Religious Conversion

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MP High Court Refuses To Quash FIR Against Three Accused Of Providing Equipment Used For Advertising Religious Conversion

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