Understanding India’s ‘Anti-Conversion’ Laws

India is home to multiple religious beliefs and practices, including Hinduism, Islam, Christianity, Sikhism, Buddhism, Jainism, Zoroastrianism and Judaism. In the past, the country has been known for not only its diversity but also tolerance. It is widely believed that because of this tolerance, religions that originated in other countries/regions flourished in India. However, the use of religion in political mobilisation has over the last three decades led to the Indian society being polarised and witnessing communal violence. One of the narratives that has long been used is that members of the Christian and Muslim minorities engage in forceful conversions. As a result, several state governments have enacted Freedom of Religion Acts, commonly known as anti-conversion laws.

Definitions
Intimation: Prior Permission and Post-Intimation
Punishments in Contravention of the Laws
Conclusion
Bibliography
Footnotes

The history of the Freedom of Religion Acts dates back to the 1930s during British rule when some “princely states” enacted them.[i] Post-independence, several bills were introduced to regulate religious conversions nationally, which, however, failed to pass the parliament.

The first one to be introduced was the Indian Conversion (Regulation and Registration) Bill in 1954, which sought to enforce “licensing of missionaries and the registration of conversion with government officials.” This was followed by the introduction of the Backward Communities (Religious Protection) Bill in 1960, which aimed at checking conversion of Hindus to “non-Indian religions,” identified in the Bill as Islam, Christianity, Judaism and Zoroastrianism. In 1979, a Freedom of Religion Bill sought “official curbs on inter-religious conversion.”[ii]

India’s first Prime Minister, Jawaharlal Nehru, was strongly opposed to a national law regulating religious conversions. He has been quoted as saying:

“I fear this bill… will not help very much in suppressing the evil methods [of gaining converts], but might very well be the cause of great harassment to a large number of people. Also, we have to take into consideration that, however carefully you define these matters, you cannot find really proper phraseology for them… The major evils of coercion and deception can be dealt with under the general law. It may be difficult to obtain proof but so is it difficult to obtain proof in the case of many other offences, but to suggest that there should be a licensing system for propagating a faith is not proper. It would lead in its wake to the police having too large a power of interference.”[iii]

However, some states succeeded in enacting anti-conversion laws thanks at least partly to the controversial Niyogi Committee Report on Christian Missionary Activities, published by the Government of Madhya Pradesh in 1956.

The Committee, chaired by M. Bhawani Shankar Niyogi, a retired Chief Justice of the Nagpur High Court, included five other members – M.B. Pathak, Ghanshyam Singh Gupta, S.K. George, Ratanlal Malaviya and Bhanu Pratap Singh.

The report recommended “legal prohibition” of religious conversions that are not “completely voluntary.” It further recommended that “any attempt by force or fraud, or threats of illicit means or grants of financial or other aid, or by fraudulent means or promises, or by moral and material assistance, or by taking advantage of any person’s inexperience or confidence, or by exploiting any person’s necessity, spiritual (mental) weakness or thoughtlessness, or, in general, any attempt or effort (whether successful or not), directly or indirectly to penetrate into the religious conscience of persons (whether of age or underage) of another faith, for the purpose of consciously altering their religious conscience or faith, so as to agree with the ideas or convictions of the proselytizing party should be absolutely prohibited.”[iv]

The first of the post-independence anti-conversion law – Orissa Freedom of Religion Act – came into force in 1967. A year later, in 1968, the Madhya Pradesh Dharma Swatantrya Adhinayam was enacted. The Madhya Pradesh law was mimicked by the state of Arunachal Pradesh as the Arunachal Pradesh Freedom of Indigenous Faith Act of 1978. However, its Rules are yet to be framed, as a result of which the Act has never been implemented.

In the year 2000, when Chhattisgarh was carved out of Madhya Pradesh as a separate state, it adopted the anti-conversion law as the Chhattisgarh Dharma Swatantrya Adhinayam, 1968.

In 2002, the Tamil Nadu state assembly passed the Tamil Nadu Prohibition of Forcible Conversion of Religion Ordinance. However, it was withdrawn in 2004.[v]

In April 2006, the BJP-led government in Rajasthan passed a similar freedom of religion bill. However, assent of the President of India is still awaited after the Bill was forwarded to the President by the then Governor of Rajasthan, Pratibha Patil.

In 2006, the Chhattisgarh Dharma Swatantrya Sanshodhan Vidheyak was introduced to make the existing Chhattisgarh Dharma Swatantrya Adhinayam more stringent by enhancing the punishment under the Act and by introducing provisions so as not to treat “reconversion” to one’s ancestors’ religion as conversion as well as requiring permission to be sought from the concerned District Magistrate before a conversion ceremony is performed. However, the assent of the state’s Governor was awaited as of December 2020.

In 2003, the Gujarat Freedom of Religion Act was enacted. In 2006, the Himachal Pradesh Freedom of Religion Act came into force. In 2017, the Jharkhand Freedom of Religion Act was enacted. In 2018, the Uttarakhand Freedom of Religion Act came into force.

In 2019, Himachal Pradesh introduced a new Freedom of Religion Bill to repeal and replace the Act of 2006,[vi] introducing new provisions, including to prohibit conversion by misrepresentation, undue influence, by marriage, etc. The punishments for contravention of the provisions of the new law were also more stringent than the previous law. The Bill was passed and enacted although it included the provisions regarding prior permission and no requirement of notice if a person re-converts to his parent religion that had been struck down by the Himachal Pradesh High Court in 2012.[vii]

While all anti-conversion legislations follow the general framework of the first legislation i.e. the Orissa Freedom of Religion Act, 1967, the later legislations have become harsher and more restrictive, in particular the Uttarakhand Freedom of Religion Act of 2018.

Definitions

The Freedom of Religion Acts claim to prohibit conversions by force, fraud and inducement/ allurement.

The Acts in Orissa, Madhya Pradesh, Chhattisgarh, Himachal Pradesh and Jharkhand define conversion as renouncing one religion and adopting another.[viii] The Arunachal Pradesh Act has a minor difference in the definition of conversion. It says that “conversion” means renouncing one religious faith and adopting another religious faith, and that the term (to) “convert” shall be construed accordingly.[ix]

Meanwhile, the Gujarat Act uses the term “convert” rather than “conversion” and defines it as making “one person renounce one religion and adopt another religion.”[x] In 2017, Jharkhand followed the same language and added the term “convert” in its law as well.[xi]

The Uttarakhand Act preferred to use the term “convincing for conversion” and defined it as making one person agree to renounce one’s religion and adopt another religion.[xii]

The term “force” is defined in all the Acts as more or less as “a threat of injury of any kind including the threat of divine displeasure or social ex-communication.”[xiii]

All the Acts use “fraud” and “fraudulent” interchangeably with the same definition as “misrepresentation or any other fraudulent contrivance.”[xiv]

The term “inducement” is defined as “shall include the offer of any gratification, either in cash or in kind and shall also include the grant of any benefit, either pecuniary or otherwise” in three of the states,[xv] whereas four of the states use the term “allurement” and defined it as “offer of any temptation in the form of – (i) any gift or gratification either in cash or kind; (ii) grant of any material benefit, either monetary or otherwise.”[xvi] The Uttarakhand Act defines the term “allurement” more specifically as “allurement means and includes the offer of any temptation in the form of gift or gratification or material benefit, either in cash or kind or employment, free education in reputed school run by any religious body, easy money, better lifestyle, divine pleasure or otherwise.[xvii]

The Uttarakhand Act has also defined certain terms which are not included in the previous Acts passed by the other seven states. It includes the term “undue influence,” which “means the unconscientious use by one person of his power or influence over another in order to persuade the other to act in accordance with the will of the person exercising such influence.”[xviii] It also defines “religion” as any organised system of faith, belief, worship or lifestyle, as prevailing in India or any part of it, and defined under any law or custom for the time being in force.[xix] Further, it defines “religious priest” as priest of any religion who performs purification Sanskar or conversion ceremony of any religion and by whatever name he is called such as pujari, pandit, mullah, maulvi, father etc.[xx]

Intimation: Prior Permission and Post-Intimation

All the Acts require that a person who is converting or overseeing the religious ceremony of a convert inform the district authorities by completing a form prescribed in the legislation. The intimation can be prior to conversion or in some cases post conversion. In some of the states, the person or religious priest conducting the conversion ceremony is also required to send an intimation either prior to such a ceremony or post conversion.

Orissa Freedom of Religion Act, 1967

Madhya Pradesh Freedom of Religion Act, 1968

Arunachal Pradesh Freedom of Religion Act, 1978

Chhattisgarh Dharma Swatantrya Adhinayam, 1968

Gujarat Freedom of Religion Act, 2003

Himachal Pradesh Freedom of Religion Act, 2006

Jharkhand Freedom of Religion Act, 2017

Uttarakhand Freedom of Religion Act, 2018

Sanction required before prosecution

Before prosecution of any offender under the law, sanction is required from the Magistrate or any such authority not lower than a Sub divisional officer.

Permission or intimation or declaration of conversion

Person intending to convert shall give a declaration before a Magistrate prior to conversion.

Person conducting conversion ceremony is required to give an intimation to the District Magistrate fifteen days before the ceremony

Intimation required to be given to the District Magistrate (DM) seven days after any conversion ceremony by the person conducting the ceremony.

Intimation to be given after the conversion ceremony to the Deputy Commissioner of the District by the person who has performed the conversion. However, no time frame is given as to how many days post the conversion the intimation should be given to the Deputy Commissioner.

Intimation required to be given to the District Magistrate seven days after any conversion ceremony by the person conducting the ceremony.

A person who has converted his religion through a conversion ceremony is required to send an intimation to the DM within ten days after such ceremony.

Prior permission required from the DM by a person who conducts a conversion ceremony.

The Himachal Pradesh High Court in CWP No. 438/2011 struck down Section 4 of the HP Freedom of Religion Act, 2006 that had required any person intending to convert his religion to give thirty days prior notice to the District Magistrate.

A person who has converted his religion through a conversion ceremony is required to send an intimation to the DM within seven days after such ceremony.

Prior permission required from the DM by a person who conducts a conversion ceremony.

Any person who desires to convert his religion shall give a declaration at least one month in advance in the prescribed format to the District Magistrate of the District in which he is permanently resident.

The religious priest who performs a conversion ceremony shall give one month’s advance notice in the prescribed format to the District Magistrate of the district where the ceremony is proposed to be performed.

Punishments in Contravention of the Laws

	Orissa Freedom of Religion Act, 1967	Madhya Pradesh Freedom of Religion Act, 1968	Arunachal Pradesh Freedom of Religion Act, 1978	Chhattisgarh Dharma Swatantrya Adhinayam, 1968	Gujarat Freedom of Religion Act, 2003	Himachal Pradesh Freedom of Religion Act, 2006	Jharkhand Freedom of Religion Act, 2017	Uttarakhand Freedom of Religion Act, 2018
Offence	Cognizable and bailable						Cognizable and non bailable
Punishment in the event of contravention of law	Punishment will include imprisonment up to one year and or fine up to rupees five thousand.		Punishment will include imprisonment up to two years and fine up to rupees ten thousand for contravention of the Act. In the event of failure on the part of the person performing the conversion, the punishment is up to one year or fine up to rupees one thousand or both.	Punishment will include imprisonment up to one year and or fine up to rupees five thousand.	Punishment will include imprisonment up to three years and or fine up to rupees fifty thousand	Punishment will include imprisonment up to two years and or fine up to twenty-five thousand	Punishment will include imprisonment up to three years and or fine up to rupees fifty thousand	Punishment will include imprisonment ranging from three months to one year and fine for those who fail to give a declaration to the District Magistrate of their intention to convert at least one month in advance. Imprisonment ranging from six months to two years and fine for failure on the part of the religious priest who performs the purification Sanskar or conversion ceremony to give one month advance notice to the District Magistrate of such conversion that is about to take place.
Where person converted is a Minor/ Woman/SC/ST	Punishment will include imprisonment which can extend up to two years and or fine up to rupees ten thousand.		N/A	Punishment will include imprisonment which can extend up to two years and or fine up to rupees ten thousand.	Punishment will include imprisonment which can extend up to four years and also be liable to fine which may extend up to rupees one hundred thousand.	Punishment will include imprisonment which can extend up to three years and or fine up to rupees fifty thousand.	Punishment will include imprisonment which can extend up to four years and also be liable to fine which may extend up to rupees one hundred thousand.	Punishment will include imprisonment which can extend up to no less than two years, but which can extend to seven years and shall also be liable for fine
Institution or organization violating the provisions of this Act	N/A							The person(s) in charge of the affairs of the organization or institution shall be liable for imprisonment ranging from three months to one year and fine. The registration of the organization may be cancelled, and that person/organisation disallowed from accepting any donations from India or abroad.
A marriage for the sole purpose of religious conversion, between persons belonging to different religions, for which a man converts himself or converts the woman, before or after the marriage.	N/A							The marriage may be declared null and void, by the Court having jurisdiction to such a case, on a petition presented by either the husband or the wife against the other.

The Uttarakhand Act differs from the ones in the other states as it stipulates that if any institution or organisation violates the provisions of the Act, the person or persons in charge of the affairs of the organisation or institution, as the case may be, shall be subject to punishment and the registration of the organisation or institution under any law for the time being in force may be cancelled after giving reasonable opportunity of hearing.[xxi]

Conclusion

While the Freedom of Religion Acts purport to protect freedom of religion by prohibiting only those religious conversions which are carried out by forceful or fraudulent means, it makes every religious conversion suspect and the subject of an enquiry. Consequently, instead of promoting religious freedom, the laws function as a mechanism to restrict the freedom of religion and conscience of individuals. The definitions contained in the Acts are vague and manifestly arbitrary as they render it impossible for a person of average intelligence to be certain of their meaning and scope.

The definition of the term “force” as “threat of divine displeasure” unjustifiably impinges on possible interactions between potential converts and those seeking to propagate their faith. It restricts the latter from informing the former about nonadherence, for example, as that may involve teachings on hell or God’s wrath. And without being informed, a potential convert cannot meaningfully exercise his or her freedom to change religion.[xxii]

The definition of conversion in the Acts contemplates a pre-existing religion in the life of a person and does not consider atheists and agnostics. If the intention of the legislature is to prohibit conversion by fraudulent means, then it should have also considered atheists and agnostics who are as vulnerable to such prohibited means as a person following a religion. Besides, when and at what time the process of conversion begins, and ends, cannot be defined precisely.

Moreover, the Acts fail to acknowledge the reality of conversion. “Conversion,” in most cases, is not a rite that a religious leader performs; it could be a personal decision that an individual makes in the intimacy of his heart. Even the mightiest potentate on earth has no right to interfere in this matter. The Supreme Court of India has held in several judgments that mere declaration of conversion cannot be taken as evidence of conversion; “but a bonafide intention to be converted in the Hindu faith, accompanied by conduct unequivocally expressing the intention may be sufficient evidence for conversion. No formal ceremony for purification or expiation is necessary to effectuate conversion.”[xxiii]

While the assumption of the anti-conversion laws is that conversion requires an external agency and is not a matter of choice or personal decision, the Uttarakhand law has gone one step further by bringing under its purview interreligious marriages. Section 6 of the law prohibits “an interreligious marriage, for the sole purpose of religious conversion, between persons belonging to different religions, for which a man converts himself or converts the woman, before or after the marriage.” The law will have a hindering effect on those who wish to marry a person of a different religious faith from their own and any religious conversion linked thereto.

The Uttarakhand law has traversed into uncharted territory by making even the failure to notify one’s intention to convert one’s faith a non-bailable offense punishable with a jail term. This would amount to further victimisation of a person whom the law purports to protect from forceful and fraudulent religious conversions.

The Acts also give district authorities wide and sweeping powers to inquire into both the reasons behind a religious conversion and the procedure adopted for the same. This is a gross violation of the right to freedom of association, the right to privacy and the freedom of conscience. The Acts cast an onerous burden on part of the convertee and the persons seeking to propagate their faith, without providing the required checks and balances to ensure protection against misuse of authority. The sanction required under the laws is also not required until much later after the charge-sheet is filed and trial initiated. It fails to protect innocent people being wrongly framed and charged under the Acts.

The International Covenant on Civil and Political Rights (ICCPR) also recognises in Article 18 that nothing may restrict the freedom to have or adopt a certain belief or religion — the forum internum — but the anti-conversion laws appear to be designed to restrict this very choice. The UN Human Rights Committee made it clear in General Comment No. 22 that no one should be compelled to reveal the religion to which he adheres. The requirement in some states that a person planning to convert must apply for permission from a magistrate subjects the intended convert to the will of an official who may be under pressure from religious extremists to prevent conversion from one religion but to ignore mass conversions to that religion.

Even having only to notify, rather than request permission from, a magistrate in advance of a conversion may deter potential converts, especially if the magistrate is unfavourable to the conversion. Magistrates may pass on the names of potential converts to extremists, who then may intimidate the potential convert to prevent conversion.[xxiv] The procedure, in fact, seems to be oppressive as it will deter a person from changing her or his religion as it inter alia involves the stigma of having a state inquiry.

The anti-conversion laws and related government documents discussed here construct women, Scheduled Tribes and Scheduled Castes as victims, as well as construct converts (particularly group converts) as passive dupes of the machinations of active converters. Such language, used in these Acts, reduces the convert to a victim — particularly converts from groups seen as vulnerable, commonly referred to as the “weaker sections” of the Indian society. These laws perpetuate a longstanding tendency to see converts or potential converts as victims.[xxv]

In the name of protecting the weaker sections by providing harsher punishment for converting a woman or a member of a Scheduled Caste or a Scheduled Tribe, the Acts prevent the mobility and freedom of conscience of these communities that have been victims of the repressive caste system is some Hindu societies.

The purpose of the Acts seem to be not so much as to “protect” them but to “prevent” them from free and voluntary conversion. Therefore, the Acts can be seen as discriminatory, and may lead to hostile discrimination and also directly infringe upon the right to life and liberty under Article 21 of the Constitution. The legislation also seems to suggest that the category of persons mentioned in the same are incapable of taking decisions concerning their lives and spiritual matters and that the State must act as their guardian.

It is a person’s prerogative and liberty to decide for herself or himself in matters related to her or his conscience. The procedures laid down in the Acts can, therefore, be seen as a direct annihilation of a person’s right to privacy and liberty. For, under the provisions of these Acts, a person’s decision regarding her or his faith is subject to the approval and satisfaction of the State.

In Yulitha Hyde & Others v. State of Orissa & Others,[xxvi] the High Court of Orissa while declaring the Orissa Act unconstitutional held that “the Act essentially deals with the subject-matter of ‘religion’ and its provisions do not indeed relate to ‘public order.’” The court further held, “Article 25(1) guarantees propagation of religion and conversion is a part of the Christian religion. Prohibition of conversion by ‘force’ or by ‘fraud’ as defined by the Act would be covered by the limitation subject to which the right is guaranteed under Article 25(1). The definition of the term ‘inducement’ is vague, and many proselytizing activities may be covered by the definition and the restriction in Article 25(1) cannot be said to cover the wide definition. The State Legislature has no power to enact the impugned legislation which in pith and substance is a law relating to religion.”

However, in 1977, the Supreme Court of India, in Rev. Stainislaus v. State of Madhya Pradesh & Others,[xxvii] overruled this decision and upheld the constitutional validity of these laws. The Supreme Court, while upholding both state laws as constitutional, echoed Niyogi’s concern about public order.[xxviii]

“It is not in controversy that the Madhya Pradesh Act provides for the prohibition of conversion from one religion to another by use of force or allurement, or by fraudulent means, and matters incidental thereto. The expressions ‘allurement’ and ‘fraud’ have been defined by the Act. Section 3 of the Act prohibits conversion by use of force or by allurement or by fraudulent means and Section 4 penalises such forcible conversion. Similarly, Section 3 of the Orissa Act prohibits forcible conversion by the use of force or by inducement or by any fraudulent means, and Section 4 penalises such forcible conversion. The Acts therefore dearly provide for the maintenance of public order for, if forcible conversion had not been prohibited, that would have created public disorder in the States.”[xxix]

The proviso to Section 4(1) of the Himachal Pradesh Act, which provided that no notice shall be required if a person reverts back to her or his original religion, was struck down by the High Court of Himachal Pradesh in 2012 along with the rest of the section and the corresponding Rule 3. The court held:

“We are unable to comprehend how the issuance of a notice by a convertee will prevent conversions by ‘fraud,’ ‘force’ or ‘inducement.’ In fact, this may open a Pandora’s box and once notice is issued, this may lead to conflicts between rival religious outfits and groups. No material has been placed on record by the State to show that there has been any adverse effect on public order by any conversion in the State whether prior to or after the enactment of the Himachal Pradesh Act. In fact, till date only one case has been registered under this Act.”

It further held, “We fail to understand the rationale why if a person is to revert back to his original religion, no notice is required. It was urged before us that since he was born in his religion and knows his religion well, therefore, it was thought that while reverting back to his original religion, no notice be issued. This argument does not satisfy the parameters of Article 14 of the Constitution of India. Supposing a person born in religion A converts to religion B at the age of 20 and wants to convert back to religion A at the age of 50, he has spent many more years, that too mature years, being a follower of religion B. Why should he not be required to give notice?”[xxx]

Similarly, the Bombay High Court, in Dr. Ranjeet Mohite and Ors Vs. UOI and Ors, held that no authority which is a State within the meaning of Article 12 of the Constitution of India or any of its agency or instrumentality can infringe the fundamental right to freedom of conscience. Any individual in exercise of right of freedom of conscience is entitled to carry an opinion and express an opinion that he does not follow any religion or any religious tenet... He cannot to be compelled to state that he professes a particular religion.[xxxi]

India’s anti-conversion laws do not appear to have any basis. First, there is little evidence for the unstated but obvious premise of the laws — that Muslims and Christians are forcibly converting the poor and disadvantaged away from Hinduism. The laws do not recognise that converts have any agency in their conversions; all conversions away from Hinduism are presumed problematic and open to investigation.[xxxii]

Moreover, the laws are overly broad given the lack of detailed definitions, particularly of the terms under which conversions are not allowed – including “force,” “allurement,” “inducement,” and “fraud.” The ICCPR recognises in Article 19 the freedom to express one’s beliefs, and in combination with Article 18’s guarantee of freedom of religion, people must be allowed to share their religious beliefs.[xxxiii]

These laws, therefore, limit the constitutionally protected fundamental rights of religious minorities which reside in the states where the laws are presently in force as well as discourage all people from choosing a religion or faith of their choice.

Bibliography

n.d.

Arora, Tehmina. 2012. "India’s Defiance of religious freedom, A briefing on “anti-conversion” laws." The International Journal for Religious Freedom (IJRF) Vol 5 (1): 59–71. https://iirf.eu/site/assets/files/92052/ijrf_vol5-1.pdf

n.d. "Arunachal Pradesh Freedom of Religion Act, 1978, Section 2(b)."

Dr. Ranjeet Suryakant Mohit v. Union of India. 2014. Public Interest Litigation No.139 of 2010 (High Court of Bombay). https://indiankanoon.org/doc/187922220/

Dr. Ranjeet Suryakant Mohit v. Union of India. 2014. Public Interest Litigation No.139 of 2010 (High Court of Bombay. ). https://indiankanoon.org/doc/187922220/

Evangelical Fellowship of India & Another v. State of Himachal Pradesh. 2012. CWP 438 of 2011 (High Court of Himachal Pradesh). https://highcourt.hp.gov.in/cmis/casest/cis/generatenew.php?path=../data/judgment/old/&fname=CWP4382011.pdf&smflag=N

Fischer, Meghan G. n.d.

Fischer, Meghan G. 2018. "Anti-Conversion Laws and the International Response." Penn State Journal of Law and International Affairs 6 (1).

n.d. "Gujarat Freedom of Religion Act, 2003, Section 2(b)."

Jenkins, Laura Dudley. n.d. "Legal Limits on Religious Conversion in India, 71 Law and Contemporary Problems 109-128 (Spring 2008)." Duke Law Scholarship Repository 71 (2). https://scholarship.law.duke.edu/lcp/vol71/iss2/9/

n.d. "Jharkhand Freedom of Religion Act, 2017, Section 2(c)."

n.d. "Madhya Pradesh Act, Chhattisgarh Dharma Swatantrya Adhiniyam and Gujarat Act-Sec.2(a). ."

Mrs. Yulitha Hyde & Ors. v. State of Orissa & Ors. 1972. O.J.C. Nos. 185, 186 and 217 of 1969 (High Court of Orissa). https://indiankanoon.org/doc/453517/

n.d. "Orissa Act and Himachal Pradesh Act-Sec.2(c). Madhya Pradesh Act, Chhattisgarh Dharma Swatantrya Adhiniyam, Gujarat Act and Uttarakhand Act-Sec.2(d). Arunachal Pradesh Act and Jharkhand Act-Sec.2(e)."

n.d. "Orissa Act and Himachal Pradesh Act-Sec.2(d). Arunachal Pradesh Act-Sec.2(f)."

n.d. "Orissa Act, Himachal Pradesh Act-Sec. 2(b). Madhya Pradesh Act, Chhattisgarh Dharma Swatantrya Adhiniyam, Gujarat Act, Uttarakhand Act-Sec.2(c). Jharkhand Act-Sec. 2(d)."

n.d. "Orissa Freedom of Religion Act, 1967, Madhya Pradesh Freedom of Religion Act, 1968, Chhattisgarh Dharma Swatantrya Adhiniyam, 1968, the Himachal Pradesh Freedom of Religion Act, 2006, Sections 2(a).Jharkhand Freedom of Religion Act, 2017, Section 2(b)."

Perumal Nadar (Dead) By L.R.S vs Ponnuswami. 1970. Civil Appeal No. 354 of 1967 (Supreme Court of India). https://indiankanoon.org/doc/1421679/#:~:text=HEADNOTE%3A%20One%20Perumal%20Nadar%2C%20a-%20Hindu%2C%20married%20Annapazham%2C,two%20children%20born%20of%20the%20marriage%20o-ne%20died

n.d. PRS Legislative Research. https://prsindia.org/files/bills_acts/bills_states/himachal-pradesh/2019/Bill%2013%20of%202019%20HP.pdf.

Rajagopal, Krishnadas. 2014. "Propagation without proselytization: what the law says." The Hindu. December 21. https://www.thehindu.com/sunday-anchor/propagation-without-proselytisation-what-the-law-says/article6711440.ece#:~:text=Even%20pre-Independence%20anti-conversion%20statutes%20by%20Princely%20States%20such,of%201946%20were%20specifically%20again-st%20conver

"Report of the Christianity Missionary Activities Enquiry Committee, 1956, Vol. I, Part IV." http://www.voiceofdharma.org/books/ncr/index.htm.

Rev. Stainislaus v. State of Madhya Pradesh & Others. 1977. Civil Appeal Nos. 1489. & 1511 of 1974 (Supreme Court of India). https://indiankanoon.org/doc/1308071/

Tariq Ahmad, Foreign Legal Specialist, Foreign Legal Specialist. n.d. State Anti-conversion Laws in India. https://www.loc.gov/law/help/anti-conversion-laws/india.php

n.d. "Uttarakhand Act, Section 10."

n.d. "Uttarakhand Act-Sec.2(a) ."

n.d. "Uttarakhand Freedom of Religion Act, 2018, Section 2(b)."

Footnotes

[i] (Rajagopal 2014)

[ii] (Tariq Ahmad n.d.)

[iii] (Arora 2012)

[iv] (Report of the Christianity Missionary Activities Enquiry Committee, 1956, Vol. I, Part IV 1956)

[v] (Jenkins n.d.)

[vi] (PRS Legislative Research n.d.)

[vii] (Evangelical Fellowship of India & Another v. State of Himachal Pradesh 2012)

[viii] (Orissa Freedom of Religion Act, 1967, Madhya Pradesh Freedom of Religion Act, 1968, Chhattisgarh Dharma Swatantrya Adhiniyam, 1968, the Himachal Pradesh Freedom of Religion Act, 2006, Sections 2(a).Jharkhand Freedom of Religion Act, 2017, Section 2(b). n.d.)

[ix] (Arunachal Pradesh Freedom of Religion Act, 1978, Section 2(b). n.d.)

[x] (Gujarat Freedom of Religion Act, 2003, Section 2(b). n.d.)

[xi] (Jharkhand Freedom of Religion Act, 2017, Section 2(c). n.d.)

[xii] (Uttarakhand Freedom of Religion Act, 2018, Section 2(b). n.d.)

[xiii] (Orissa Act, Himachal Pradesh Act-Sec. 2(b). Madhya Pradesh Act, Chhattisgarh Dharma Swatantrya Adhiniyam, Gujarat Act, Uttarakhand Act-Sec.2(c). Jharkhand Act-Sec. 2(d) n.d.)

[xiv] (Orissa Act and Himachal Pradesh Act-Sec.2(c). Madhya Pradesh Act, Chhattisgarh Dharma Swatantrya Adhiniyam, Gujarat Act and Uttarakhand Act-Sec.2(d). Arunachal Pradesh Act and Jharkhand Act-Sec.2(e) n.d.)

[xv] (Orissa Act and Himachal Pradesh Act-Sec.2(d). Arunachal Pradesh Act-Sec.2(f). n.d.)

[xvi] (Madhya Pradesh Act, Chhattisgarh Dharma Swatantrya Adhiniyam and Gujarat Act-Sec.2(a). n.d.)

[xvii] (Uttarakhand Act-Sec.2(a) n.d.)

[xviii] Id Clause (h)

[xix] Id Clause (i)

[xx] Id Clause (j)

[xxi] (Uttarakhand Act, Section 10 n.d.)

[xxii]supra note 3 at 64

[xxiii] (Perumal Nadar (Dead) By L.R.S vs Ponnuswami 1970)

[xxiv] (Fischer, Anti-Conversion Laws and the International Response 2018)

[xxv]supra note 5 at 124

[xxvi] (Mrs. Yulitha Hyde & Ors. v. State of Orissa & Ors 1972)

[xxvii] (Rev. Stainislaus v. State of Madhya Pradesh & Others 1977)

[xxviii] supra note 5 at 115

[xxix]supra note 27 at 683

[xxx]supra note 7 at 22-24

[xxxi] (Dr. Ranjeet Suryakant Mohit v. Union of India 2014)

[xxxii]supra note 24 at 20

[xxxiii] Id