The Allahabad High Court recently refused to quash a criminal case filed against two class XII Muslim students accused of forcing Islamic religious beliefs on a Hindu student and attempting to convert her religion [Aleena alias Aleena Parveen and another v State of UP and Others].

A Division Bench of Justice JJ Munir and Justice Tarun Saxena also said that forced religious conversion allegations among youngsters was particularly disturbing.

The Court noted that the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 was enacted to curtail such situations in society, where certain persons thrust their religion upon others.

“If this kind of a trend comes to be seen amongst young people, it is all the more disturbing. This is time in their lives when they should be thinking more towards developing their skills in different fields of education and dedicate themselves in the service of the society and the nation,” the Court added.

The Court further observed that if the 2021 anti-conversion law is stopped in its tracks at the very early stages of its enforcement, it would bog down the statute and frustrate its purpose. However, it also cautioned against false implications under the anti-conversion law.

“This does not mean that false implications under a new statute are to be encouraged, but, at the same time, the purpose, for which the statute has been enacted, cannot be subverted by snuffing out prosecutions brought on tangible materials at the threshold,” the Bench said.

The case before the Court involved allegations that a group of Muslim girls tried to force their religious beliefs on a Hindu girl who attended the same tuition centre.

The criminal case was registered on a complaint filed by the Hindu student's brother (complainant), who alleged that his sister was compelled to wear a burqa by the accused and was being forced to accept the accused's religion, Islam.

The alleged victim later gave a statement to the police, in which she said that such events took place during an outing in December 2025. She said that after coaching classes, she went out with the accused Muslim students who later forced her to wear a burqa all day and tried to get her to eat non-vegetarian food.

The victim reportedly said that when she refused to eat meat, the accused suggested that she try the gravy. The Court also took note of a statement that the accused tried to get the Hindu student to accept Islam and forbade her to speak about these things to her parents.

Three of the accused Muslim students later approached the High Court to quash the anti-conversion case filed against them, maintaining that the allegations were false.

They said that the complainant had been harassing one of the Muslim girls. When she complained, he lodged the present case as counter-blast under the anti-conversion law, the petitioners said.

Though three students moved the Court to quash the case, one of them eventually withdrew her plea. By an April 16 order, the High Court has now dismissed the remaining two pleas.

The Court found that the victim in her statement had claimed that her Muslim friends had forced her to wear the veil and would also allure her to eat non-vegetarian food. The Court also noted that one of the accused had asked her to adopt Islam as her faith.

“We notice from the Case Diary that the victim was caught on a Closed-Circuit Television (CCTV) camera, located in an alley, where, she was forced to wear the veil (burqa) by the petitioner and the other co-accused, including Aleena, who has withdrawn her writ petition,” it added.

The Court further said that though the investigation was still ongoing, the material collected so far prima facie discloses a case that requires a thorough probe.

“The submissions advanced by learned Counsel for the petitioners that it is a mala fide FIR, is absolutely not borne out by the record. There is no FIR earlier lodged that it was the third respondent who was stalking or harassing Aleena or had proposed to her. Quite apart, the stand of the victim before the learned Judicial Magistrate cannot be trashed. It carries all the necessary facts, which would prima facie attract the provisions of Section 3 and 5(1) of the Act of 2021,” it said, while dismissing the petitions seeking the quashing of the FIR.

Advocates Shiv Shanker Mishra and Ashutosh Upadhyay appeared for the petitioners.

Advocate Chandra Vijai Singh appeared for the complainant.

Advocate Shashi Shekhar Tiwari appeared for the State. 

[Read Judgment]