MP HC upholds charges against accused in Christian conversion case, says providing equipment for inducement campaign warrants trial
The Court noted that the accused, including Rai Singh, were allegedly involved in providing equipment used for advertising promises and inducements made during the alleged conversion drive.
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The Madhya Pradesh High Court has upheld the framing of charges against five accused in an alleged religious conversion case, holding that the material collected during the investigation prima facie indicated their involvement in facilitating an inducement campaign aimed at persuading villagers to embrace Christianity.
The Court noted that the accused, including Rai Singh, were allegedly involved in providing equipment used for advertising promises and inducements made during the alleged conversion drive.
"The averments contained in the complaint... prima facie fall within the ambit of 'allurement' as defined under Section 2(a) of the Act of 2021. The material collected during the course of investigation also prima facie discloses the involvement of the revision petitioners... as they are alleged to have provided the equipment used for advertising the alleged inducement for religious conversion," the Court observed.
Alleged conversion meeting
The complaint alleged that participants were promised free medical treatment, quality education, and financial assistance of ₹50,000 if they embraced Christianity. Acting on the complaint, police registered an FIR under the Madhya Pradesh Freedom of Religion Act and launched an investigation.
During the probe, police identified several accused, while proceedings against two juveniles were separated and placed before the Juvenile Justice Board. A charge sheet was subsequently filed against Manju, Kiran, Jagram, Rai Singh, and Mithun.
Court rejects discharge plea
The Bench also rejected the argument that mandatory procedural requirements under Section 4 of the Madhya Pradesh Freedom of Religion Act had not been followed. It noted that the complainant himself was allegedly present during the meeting where inducements for conversion were made, making the allegations sufficient to justify continuation of the prosecution.
Finding no legal infirmity in the trial court's order, the High Court dismissed the revision petition and directed that the criminal proceedings continue.
Continuing judicial backing for the Anti-Conversion Law
The ruling adds to a series of judicial decisions upholding prosecutions under the Madhya Pradesh Freedom of Religion Act, 2021, which criminalises religious conversion through force, fraud, coercion or allurement. The Act defines "allurement" broadly to include promises of financial benefits, better education, free medical treatment or other material incentives intended to induce religious conversion.
Justice Gajendra Singh dismissed a criminal revision petition challenging the trial court's order framing charges under Sections 3 and 5 of the Madhya Pradesh Freedom of Religion Act, 2021, along with Section 61(2) of the Bharatiya Nyaya Sanhita (BNS), observing that the allegations and evidence on record were sufficient to proceed to trial.
The Court noted that the accused, including Rai Singh, were allegedly involved in providing equipment used for advertising promises and inducements made during the alleged conversion drive.
"The averments contained in the complaint... prima facie fall within the ambit of 'allurement' as defined under Section 2(a) of the Act of 2021. The material collected during the course of investigation also prima facie discloses the involvement of the revision petitioners... as they are alleged to have provided the equipment used for advertising the alleged inducement for religious conversion," the Court observed.
Alleged conversion meeting
The case arose from a complaint lodged by Gajraj Singh before the Sonkatch Police Station in Dewas district. According to the complaint, a gathering was organised at the residence of one Bhaggu Jiaji, where villagers were allegedly encouraged to convert to Christianity by offering various inducements.
The complaint alleged that participants were promised free medical treatment, quality education, and financial assistance of ₹50,000 if they embraced Christianity. Acting on the complaint, police registered an FIR under the Madhya Pradesh Freedom of Religion Act and launched an investigation.
During the probe, police identified several accused, while proceedings against two juveniles were separated and placed before the Juvenile Justice Board. A charge sheet was subsequently filed against Manju, Kiran, Jagram, Rai Singh, and Mithun.
Court rejects discharge plea
Before the High Court, the accused argued that the ingredients of the offences were not made out and sought discharge. However, the Court reiterated the settled legal position that at the stage of framing charges, courts are only required to determine whether a prima facie case exists and cannot conduct a mini-trial by weighing the evidence in detail.
The Bench also rejected the argument that mandatory procedural requirements under Section 4 of the Madhya Pradesh Freedom of Religion Act had not been followed. It noted that the complainant himself was allegedly present during the meeting where inducements for conversion were made, making the allegations sufficient to justify continuation of the prosecution.
Finding no legal infirmity in the trial court's order, the High Court dismissed the revision petition and directed that the criminal proceedings continue.
Continuing judicial backing for the Anti-Conversion Law
The ruling adds to a series of judicial decisions upholding prosecutions under the Madhya Pradesh Freedom of Religion Act, 2021, which criminalises religious conversion through force, fraud, coercion or allurement. The Act defines "allurement" broadly to include promises of financial benefits, better education, free medical treatment or other material incentives intended to induce religious conversion.