Existence of a service dispute does not warrant quashing an FIR for forced religious conversion when prima facie allegations are made.

The petitioner, Principal of Sacred Heart Convent High School, sought quashment of FIR No. 36/2021 registered under Sections 3 and 5 of the Madhya Pradesh Freedom of Religion Act, 2021.

The complainant, a former teacher at the school, alleged that the petitioner pressured and induced her to convert from Hinduism to Christianity, eventually terminating her services upon her refusal.

The petitioner contended the FIR was maliciously filed as a retaliatory measure following the complainant’s termination for poor performance on July 17, 2020.

Charge-sheet was filed on March 28, 2022, during the pendency of this petition.

1. Whether the FIR and subsequent criminal proceedings should be quashed on the grounds of being manifestly attended with *mala fide* or personal grudge.

2. Whether the allegations in the FIR, taken at face value, disclose the commission of a cognizable offence under the Madhya Pradesh Freedom of Religion Act, 2021.

The court primarily applied Sections 3 and 5 of the Madhya Pradesh Freedom of Religion Act, 2021, which prohibit unlawful religious conversion.

It relied on the seminal precedent *State of Haryana v. Bhajan Lal (1992)*, which established that while courts can quash proceedings initiated with ulterior motives for wreaking vengeance, such power must be used sparingly and not to evaluate the reliability of allegations.

Furthermore, the court applied principles from *Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra (2021)*, which mandates that courts should not thwart investigations into cognizable offences unless no offence is disclosed.

It also noted *Mamta Shailesh Chandra v. State of Uttarakhand (2024)*, affirming that filing a charge-sheet does not bar a quashment petition.

The court observed that the complainant’s allegations specifically detailed inducement and pressure to convert, which *prima facie* constitute offences under the Act.

While the petitioner argued that the service dispute proved *mala fide* intent, the court found that the complainant had raised allegations of forced conversion even prior to the formal lodging of the FIR, as evidenced by the petitioner’s own correspondence to the police.

Following the *Bhajan Lal* and *Neeharika Infrastructure* standards, the court refused to embark on an inquiry into the "reliability or genuineness" of the allegations at this preliminary stage.

The court determined that the existence of a service dispute could be a valid defense during trial but was insufficient to quash the proceedings as "manifestly malicious" given the consistency of the complainant’s statements, including those recorded under Section 164 of the Cr.P.C.

The court concluded that it was not a fit case for quashment under Section 482 of Cr.P.C. as the materials in the charge-sheet and the Section 164 statement disclosed a cognizable offence.

Consequently, the petition was dismissed, and the petitioner was left to prove her innocence during the trial.