The proceedings originated from a complaint lodged on 20 June 2025 by Gajraj Singh. The complainant alleged that a gathering held at the residence of Bhaggu Jiaji was used to induce villagers to embrace Christianity by promising free medical treatment, quality education and a cash incentive of fifty thousand rupees per convert. On the basis of this complaint, a first information report was registered against five individuals identified as Manju, Kiran, Jagram, M and S. Subsequent investigation revealed that M and S were minors, prompting the trial court to frame charges only against Jagram, Manju Singh and Kiran. The three accused filed a revision petition seeking to quash the FIR, contending that the complaint was not maintainable under Section 4 of the Madhya Pradesh Freedom of Religion Act, 2021 and that no sufficient material existed to proceed against them.
Court’s View on the Maintainability of the Complaint
The Division Bench comprising Justices Vijay Kumar Shukla and Alok Awasthi examined the objection regarding the complainant’s locus standi. The Bench observed that the complainant himself was present at the meeting where the alleged inducement took place. Consequently, the Court concluded that the complaint satisfied the requirements of Section 4 of the Act and was therefore maintainable. The Bench emphasized that the presence of the complainant at the event negated the argument that the complaint was filed by an unauthorized person.
Application of Legal Principles Governing Charge Framing
In addressing the revision petition, the Court referred to the scope of Article 227 of the Code of Criminal Procedure and relied on the precedents of State of Rajasthan v Ashok Kumar Kashyap and CBI v Aryan Singh. It reiterated that at the stage of framing charges the court is not required to conduct a mini‑trial or to appreciate evidence as would be done during a regular trial. The sole inquiry is whether sufficient material exists to proceed against the accused. Applying this settled principle, the Bench held that the material gathered during the investigation prima facie disclosed the involvement of the revision petitioners, who were alleged to have supplied the equipment used for advertising the alleged inducement for religious conversion.
Assessment of the Alleged Allurement
The Bench then turned to the substantive allegation of allurement defined under Section 2(a) of the Madhya Pradesh Freedom of Religion Act, 2021. After examining the complaint, the investigation report and the statements recorded, the Court found that the available evidence prima facie established the existence of allurement. The promises of free medical treatment, education and a monetary benefit were held to fall within the ambit of allurement as contemplated by the statute. The provision of equipment for advertising such inducement was deemed to link the revision petitioners directly to the alleged offence.