MP High Court Refuses to Quash FIR Against Principal of Sacred Heart Convent High School in Forced Conversion Case

Madhya Pradesh High Court has reiterated that while exercising powers under Section 482 of the Code of Criminal Procedure, the Court cannot evaluate the truth or reliability of allegations in an FIR if the complaint prima facie discloses a cognizable offence.

On 09 March 2026, the Madhya Pradesh High Court dismissed a petition seeking quashing of an FIR registered under Sections 3 and 5 of the Madhya Pradesh Freedom of Religion Act, 2021. Justice Vinay Saraf held that the allegations of pressuring a teacher to convert her religion from Hinduism to Christianity were serious in nature and supported by the complainant’s statement recorded under Section 164 CrPC, and therefore warranted trial.

“Inherent Powers Under Section 482 CrPC Must Be Exercised Sparingly”

At the outset, the Court reiterated the settled principle governing the exercise of inherent powers by High Courts under Section 482 CrPC. Referring to the landmark judgment in State of Haryana v. Bhajan Lal, the Court observed:

“Power of quashing a criminal proceeding should be exercised very sparingly and with circumspection and that too in the rarest of rare cases.”

The Court emphasized that extraordinary jurisdiction under Section 482 does not permit the High Court to conduct a mini-trial or examine the credibility of allegations made in the FIR.

Background of the Case

The petitioner Sister Bhagya, Principal of Sacred Heart Convent High School, Khajuraho, approached the High Court seeking quashing of FIR No. 36/2021 registered at Police Station Khajuraho, District Chhatarpur.

The FIR was lodged by Ruby Singh, a teacher who had been working in the school since 2016. The complainant alleged that the petitioner repeatedly pressured and induced her to convert her religion from Hinduism to Christianity. According to the complaint, when she refused to convert, she was subjected to harassment and ultimately terminated from her employment.

The petitioner argued that the allegations were false and motivated by a service dispute, contending that the complainant had been removed from service due to unsatisfactory performance and disobedience.

Petitioner’s Argument: FIR Filed Due to Service Dispute

Counsel for the petitioner argued that the complainant’s services had been terminated on 17 July 2020 due to poor performance, and all dues had been paid.

It was further contended that after her termination, the complainant began threatening the school authorities and attempted to enter the premises, prompting the petitioner to seek police protection. According to the petitioner, the FIR was lodged maliciously to settle personal scores arising from the employment dispute.

Reliance was placed on Bhajan Lal’s case and the Supreme Court decision in Mamta Shailesh Chandra v. State of Uttarakhand, to argue that criminal proceedings instituted with mala fide intention could be quashed by the High Court.

Court Finds Prima Facie Case of Offences Under Freedom of Religion Act

The High Court, however, noted that the complainant had clearly alleged repeated pressure and inducement to convert her religion, and that she had been terminated after refusing to convert.

The Court observed:

“The allegations made in the F.I.R., if taken at their face value, constitute the ingredients of Section 3 and 5 of the Madhya Pradesh Freedom of Religion Act, 2021.”

The Court further noted that the statement of the complainant recorded before a Magistrate under Section 164 CrPC also supported the allegations, which strengthened the prima facie case against the petitioner.

Court on Scope of Judicial Interference During Investigation

Justice Vinay Saraf relied on the Supreme Court’s decision in Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, which laid down guiding principles on quashing criminal proceedings.

Reaffirming those principles, the Court observed:

“While examining an FIR for quashing, the Court cannot embark upon an enquiry as to the reliability or genuineness of the allegations made in the complaint.”

The Court emphasized that criminal proceedings should not be scuttled at the initial stage when the FIR discloses commission of a cognizable offence.

“Service Dispute May Be a Defence, But Not Ground for Quashing”

The Court also rejected the petitioner’s argument that the complaint was motivated by a service dispute.

Justice Saraf observed that the existence of an employment dispute might form part of the petitioner’s defence, but it could not be used as a ground to terminate criminal proceedings at the threshold.

The Court held:

“Service dispute may be a good ground of defence, but merely because of the service dispute, at this stage it cannot be accepted that the FIR was lodged with ulterior motive.”

The Court also noted that the complainant had raised allegations of forced conversion even prior to filing the FIR, which weakened the petitioner’s claim that the complaint was fabricated after termination.

Holding that the FIR and materials collected during investigation prima facie disclosed the commission of offences under Sections 3 and 5 of the Madhya Pradesh Freedom of Religion Act, 2021, the High Court refused to interfere.

The Court observed that the petitioner could establish her innocence during trial, but the criminal proceedings could not be quashed at this stage.

Accordingly, the petition under Section 482 CrPC was dismissed, allowing the FIR and criminal trial to proceed.

Date of Decision: 09 March 2026