The Allahabad High Court (Lucknow Bench) on December 2, 2025, quashed an FIR lodged under draconian sections of the Uttar Pradesh Anti-Conversion Act, 2021. A division bench of Justices Abdul Moin and Ms Babita Rani also warned state authorities against registering “mimeographic style”[1] orders. The observation made by the Division Bench while quashing a ‘false’ FIR lodged by a police officer in the Pratapgarh district against one Sabir Ali.
In an almost routine manner, clearly meant to harass citizens, especially those from marginalised communities who may exercise their personal choices in faith practice or in relationships, the sections applied by the Sri Hemant Yadav, Sub Inspector, Jethwara Police station, district Pratapgarh in the First Information Report dated April 26, 2025 (registered as Case Crime No. 0081 of 2025) was under Sections 5 (1), 8 (2) & 8 (6) of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021.
Sub-Inspector Hemant Yadav, the complainant in the FIR alleged that the petitioner was involved in unlawful religious conversion. In a significant Order by a Constitutional Court, not only did the Judges quash the Order but, after getting to the root of the matter –which clearly appeared to be that a false and motivated FIR had been lodged by the instant Sub-Inspector– the Court held the Principal Secretary (Home), Uttar Pradesh to account directly him to explain this conduct through filing of a personal affidavit! What cleared the matters for the Court, was the affidavit in counter filed by private respondents denying the allegations made in the FIR of any coercive conversions etc.
Interim Order of November 20, 2025
The first protective steps taken on November 20, 2025 in which interim Order the Court also stated that failure to file such affidavit before the next date, December 2, 2025 would require the Principal Secretary (Home) to appear in person, with all records of the case, before the Court. While doing so, the Court Observed that such urgent and stringent steps were required to hold the state administration at the highest level to account, as the contents of the FIR “are patently false” and aggrieved persons (citizens) are required to spend precious resources on seeking relief in patently false and motivated prosecutions. The Interim Order also protected the respondent private respondents from any harassment in any manner by the police or administration, warning of strict action were that to happen. (Para 18 of Interim Order)
Para 14 of the Interim Order dated November 20, 2025
Para 14. This Court requires the personal affidavit of the Principal Secretary (Home), Lucknow inasmuch as the Court is already deluged with the other matters which are coming before the Court and once the First Information Report is being filed by an officer of the State which prima facie appears to be false as such, this is a fit case in which the highest officer should file his affidavit indicating as to why the aforesaid First Information Report has been lodged by an officer of the State although the allegations levelled in the said First Information Report are prima facie patently false. However, the aggrieved persons are constrained to approach this Court for the redressal of their grievances whereby spending their valuable money and time and at the same time, the precious judicial time of the Court is also wasted in dealing with such cases which could have been nipped in the bud by the State itself. As such, personal affidavit would also indicate that in case such frivolous cases continue to come to the highest Court of the State as to why exemplary cost should not be imposed against the authorities who have not applied their mind while lodging the First Information Reports under the Act, 2021.
What was especially noteworthy about this case is that private respondents, 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, on record, that no incident of inducement, allurement or coercion had taken place and that they were following their religion “as per their own free will”. Details of this counter-affidavit have been recorded by the Allahabad HC in its interim order in the case dated November 20, 2025 (Paras 7 and 8), also reproduced in part in the final order in the matter dated December 2, 2025.
Paras 7 and 8 of the Interim Order of the Allahabad High Court in the Sabir Ali Case:
Para 7. Taking note of the same, in its earlier detailed order [dated N7. On the other hand, Sri Alok Pandey, Advocate who has filed a short counter affidavit today in Court on behalf of the respondents no. 5 to 8 states on the basis of averments contained in the short counter affidavit that the allegations as made in the impugned First Information Report are absolutely false, concocted, baseless and without any su any substance and no incident of religious conversion, inducement, allurement, pressure or coercion has ever taken place with the petitioner or with any of the other alleged victims.
Para 8. It is further submitted that all the private respondents have already been following their religion, social custom and traditions as per their own free will, independently and without interference or pressure from any corner. At no point of time has any of them adopted any other religion as alleged in the impugned First Information Report nor has any such step ever been undertaken or considered by them.
On that date, November 20, 2025, the Court had also 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 had then 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“.
Final Order Quashing the FIR
Finally on December 2, 2025, 14 days ago, the Division Bench recorded in Para 3 that the personal affidavit of the Principal Secretary (Home), Government of UP had been filed. Significantly, the Court observed that, in Para 4 of the Final Order, that, the State of UP conceived that the FIR may be quashed!
Para 4. Even before the averments contained in the said personal affidavit could be considered by the Court, Dr. V.K. Singh, learned Government Advocate, states that the FIR itself may be quashed by this Court.
Considering the aforesaid statement made by Dr. V.K. Singh, the Court quashed the motivated FIR and observed, in a strong observation in Para 7 of the final order dated December 2, 2025, the Allahabad High Court observed:
“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”.
(Para 7)
Counsel for the petitioners are/were Akhand Kumar Pandey, Abhishek Singh
Citizens for Justice and Peace (cjp.org.in, CJP) is the lead petitioner in the draconian ‘anti-conversion laws’ passed by those state ruled by the Bharatiya Janata Party (BJP). Today, December 16, 2025 the hearing in this matter (WP Criminal Nos 428/2020 and Nos 14/2023) is expected to address the prayer for interim stay on the most egregious provisions. In the 2025 hearings, first on April 16, 2025, and thereafter in September 2025, hearing on the main prayer of the writ petition for declaring the laws passed unconstitutional (early hearing on cases pending since December 2020) and another application filed by CJP, seeking interim relief. After first challenging the 2020-2021 amended laws of Uttar Pradesh, Uttarakhand, Madhya Pradesh and Himachal Pradesh, the CJP had, in 2023, amended their plea to include similar laws passed in Chhattisgarh, Gujarat, Haryana, Jharkhand, and Karnataka. CJP is the lead petitioner in this matter.
The Interim Order of the Allahabad HC dated November 20, 2025 may be read here
The Final Order of the Allahabad HC dated December 2, 2025 may be read here.
[1] Mimeographic refers to “photo-copy” type documents, or documents from a duplicating machine which produces copies from a stencil, now a photo-copier!
Related:
Anti-Conversion Laws: Are forced conversions a myth or reality?