This case that deals with this fundamental right of freedom of religion is Shriniwas Rav Nayak vs State of UP, 2024 which defines the limit of the right to propagate as opposed to the right to convert. The petitioner opposed the decree of Uttar Pradesh called Prohibition of Unlawful Conversion of Religion Ordinance, 2020 stating it hampered the fundamental rights regarding freedom of religion.

In the Allahabad High Court, the ordinance was passed considering that even though people have 'freedom of speech and expression to freely practice, preach and convert people to a religion, they cannot impose religion on others by force. The judgment also noted that the need to safeguard public peace and personal freedom is sufficient to prevent people from secret religious persuasion by force or fraud. This case reveals the struggle of India's balance between freedom of religion and autonomy and the state's interferences.

Case note:
Shriniwas Rav Nayak vs State of UP is a 2024 - Allahabad High Court Judgement The issue was brought before Hon'ble Rohit Ranjan Agarwal, J.
Citation
Neutral Citation No. 2024: AHC:111441

Introduction
The case to be fortunate enough to analyze is the case of Shriniwas Rav Nayak versus the State of U. P 2024 which has become a legal landmark in demarcating religious freedom under Article 25. The case looks at the vexed question of religious conversion, especially when it may be forced or where free consent was not given in the backdrop of the recently promulgated Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021. Gorgias is an important case of a conflict of interest as the freedom of religious beliefs of individuals and the state's obligation to protect people from constraints to religious change of heart. The Allahabad High Court's judgment carries certain massive legal significance for the protection and implementation of anti-conversion laws in India.

Facts of the Case:

1. Procedural Background: The applicant Shriniwas Rav Nayak was charged in court of involvement in a conversion activity in which some people were alleged to have been forced to become Christians. The application was moved based on the provision of Section 439 of the law on the Code of Criminal Procedure.
    
2. Factual Background: Specifically, the reporting style was formal, and the incident stated occurred on February 15, 2024, when the informant was invited to a party and compelled to undergo Christianization. People from the Scheduled Castes community were the clear target of the gathering organizers, who promised them greater life opportunities if they adopted the new religion. The informant fled the site and reported the incident to the police, who detained the petitioner and others.

Issues:

• Whether the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021 is unconstitutional to the extent that it violates the provision of Freedom of religion.
• Whether the act of converting under the force as is claimed by the complainants is protected under the provisions of Article 25 of the Indian Constitution.

Judgement
"If this process is allowed to be carried out, the majority population of this country would be in minority one day, and such religious congregation should be immediately stopped where the conversion is taking place and changing the religion of citizen of India," the Supreme Court stated concerning converts.

The High Court of Judicature at Allahabad dismissed the bail application stating that freedom to carry on the affairs of the religion does not include the forceful conversion of individuals, which has been prohibited in the Act.

"The Constitution grants each individual the fundamental right to profess, practice, and promote his faith. However, the individual right to freedom of conscience and religion cannot be construed as the right to go on a public campaign of conversions; freedom of religion is as much the freedom of the person converting as it is the freedom of the person being converted, the court added

Ratio Decidendi:
Concerning Section 3 of the Act the court stated that the limitations to conversion rights are constitutional as they safeguard the people from the imminent pressure and also preserve the public order.

Obiter Dicta:
Again, the judgment pointed out that religion cannot be practiced and expressed in a way that other's rights are violated along with ensuring that this right always has to be exercised within the context of public order and personal freedom.

Analysis
A key case is the Shriniwas Rav Nayak vs State of U.P. to sustain the authority of the state in controlling religious conversions to eliminate forceful conversions and preserve the law-and-order situation of the country. The judgment re-affirms that while Article 25 says that every person has the right to freedom to carry out religious activities including to profess, practice, and propagate one's religion, this is not a fundamental right to proselytization or the right to convert other people forcefully.

• Constitutional Balance: The case discusses the complexity of the conflict of interest between religious self-autonomies and the state's responsibility to provide its citizens with protection from persuasion and maintain public order. By supporting the upheld Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, the court supports the idea of the state's ability to interfere with religious issues in case of necessary regulation of public order as well as protection of people's rights.
   
• Implications for Anti-Conversion Laws: This judgment shall have a ripple effect on the implementation as well as interpretation of other similar laws in other states. It provides an example of how such courts might approach issues relating to the constitutionality of anti-conversion-related legislation, and in particular where such legislation is argued to violate religious liberty.
   
• Impact on Secularism: The decision is also important for India on the level of a secular setting. It implies that the state has a prima facie interest in regulating conduct based on religion which is likely to cause an infliction on other citizens' rights or public order. This contention may thus inform future consequentialist legal discourse on the extent of toleration of religion in an environment of diversity.

Recent development
Since the judgment, there has been a growth in the awareness of anti-conversion laws and the existence of the same in different states. The legislation has been largely struck down by courts as constitutional on grounds of the need to prevent vulnerable groups from being coerced into conversion. There may also be more legislation in store since states that would want to improve these laws in response to the judiciary may do so.

Conclusion
From the case of Shriniwas Rav Nayak vs State of U. P., one can observe a turning point related to the legal concept of the Right to Freedom of Religion in India. The Allahabad High Court's judgment thus reaffirms the proposition that the right to freedom to propagate religion does not permit the illegal conversion by force. They make a decision that enhances the capacity of the state to control religious practices that may be inclined to disrupt the order and freedom of individuals. It is argued that as India struggles in the ongoing legal and constitutional battles of religious freedom and state regulation this case will be of great use in the coming future.

End- Notes:

1. India Today, Allahabad High Court says right to freedom of religion doesn't include right to convert others; denies bail to a man accused of conversion event, July 2, 2024, https://www.indiatoday.in/law/story/allahabad-high-court-religious-conversions-man-bail-accused-event-majority-population-minority-up-2561002-2024-07-02
2. Bar & Bench, Allahabad High Court says right to freedom of religion doesn't include right to convert others; denies bail to a man accused of conversion event, July 2, 2024, https://www.barandbench.com/news/right-to-freedom-of-religion-does-not-include-right-to-convert-others-allahabad-high-court
3. Indian Kanoon, Sriniwas Rav Nayak vs State of U.P., July 9, 2024, https://indiankanoon.org/doc/148314372/
4. Sections 3/5 (1) of Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021
5. Article 25 of the Indian Constitution

Written By: Beradar Akash, Christ Academy Institute of Law, 9th Semester, BBA. LLB