04/08/2025
We invite supporters and well-wishers to join our movement against anti-conversion laws in various states of India and stand up for people of India who believe in their respective religions.
*A MODEL PETITION AGAINST ANTI CONVERSION ACTS TO SUPREME COURT OF INDIA.*
*WE INVITE SUGGESTIONS SUPPORT REGARDING THE PETITION AND THIS MOVEMENTS FROM LEGAL EXPERTS*
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**IN THE SUPREME COURT OF INDIA**
(Civil Original Jurisdiction)
**WRIT PETITION (CIVIL) UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA**
In the matter of:
Rev. Fr. Biju C Vallavanadan Secretary general, All India United Christian Front [AIUCF]
Vs.
Union of India & Ors.
**WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA SEEKING DECLARATION THAT ANTI-CONVERSION LAWS ENACTED BY CERTAIN STATES ARE UNCONSTITUTIONAL AND VOID BEING IN VIOLATION OF ARTICLE 25 OF THE CONSTITUTION**
To
The Hon’ble Chief Justice of India and His Companion Justices of the Supreme Court of India
The humble petition of the Petitioner above named:
**MOST RESPECTFULLY SHOWETH:**
1. **Facts of the Case**
a. The Petitioner is a citizen of India and is aggrieved by the increasing number of laws passed in various states termed as “anti-conversion” or “Freedom of Religion” laws.
b. Several states including Uttar Pradesh, Uttarakhand, Madhya Pradesh, Gujarat, and others have enacted stringent statutes criminalizing voluntary religious conversions under broad and vague terminology such as “force”, “allurement”, “undue influence”, or “fraudulent means”[1][2][3].
c. The enforcement of these laws has led to wide-scale harassment, criminal prosecution, violence, and discrimination against individuals exercising their fundamental right to choose and propagate religion; disproportionately affecting minorities and violating the secular ethos enshrined in the Constitution[4][5].
2. **Legal Grounds**
a. **Violation of Article 25**: Article 25(1) guarantees “freedom of conscience and the right to freely profess, practice and propagate religion” to all persons subject only to public order, morality and health[6][7][8][9]. The anti-conversion laws curtail this right by imposing prior permission, criminal penalties, and intrusive oversight[1][2].
b. **Lack of Public Order Justification**: There is no credible data or evidence that voluntary conversions disrupt public order on a scale that requires such laws. The Supreme Court in ‘Hadiya v. Ashokan K.M.’ (2018), ‘K.S. Puttaswamy v. Union of India’ (2017), and ‘Lata Singh v. State of Uttar Pradesh’ (2006) emphasized individual autonomy, privacy, and choice in religion and marriage[2][3].
c. **Chilling Effect & Disproportionate Impact**: The current laws go beyond prohibiting conversions by force or fraud (which are already punishable under general laws), and target any conversion, thus having a chilling effect on individual liberty and disproportionately impacting minorities[1][3][5].
d. **Arbitrariness and Vague Drafting**: Terms like “allurement” and “undue influence” are undefined or vague, leading to arbitrary application[1][2].
e. **Doctrine of Basic Structure**: The right to choose and change one’s religion is intrinsic to the basic structure of secular democracy as held by the Supreme Court.
3. **Prayer**
In view of the above, the Petitioner respectfully prays that this Hon’ble Court may be pleased to:
a. Issue an appropriate writ, order, or direction declaring the anti-conversion laws enacted by states such as Uttar Pradesh, Uttarakhand, Madhya Pradesh, Gujarat, Chhattisgarh, and others as unconstitutional, violative of Articles 14, 15, 21, and 25 of the Constitution;
b. Declare all provisions requiring prior notice/permission for religious conversion to be null and void;
c. Direct the Respondents to ensure the protection of individuals exercising their rights under Article 25 and prevent the misuse of anti-conversion laws to intimidate, harass, or discriminate against any individual or community;
d. Pass any other order as this Hon’ble Court may deem fit in the facts and circumstances of the case.
**AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN DUTY BOUND SHALL EVER PRAY.**
[Place], [Date]
[Signature of Petitioner/Advocate
