Rev. Stanislaus v. State of Madhya Pradesh (AIR 1977 SC 908)

CASE_TITLE: Rev. Stanislaus v. State of Madhya Pradesh (AIR 1977 SC 908)

PRIMARY_KEYWORDS: Article 25, propagation, conversion, public order, state competence

SECONDARY_KEYWORDS: anti-conversion laws, coercion, fraud, allurement, freedom of conscience

PUBLISH_DATE: 24 Oct 2025   AUTHOR_NAME: Gulzar Hashmi   LOCATION: India

Slug: rev-stanislaus-v-state-of-madhya-pradesh

The Supreme Court drew a clear line: you may share your faith, but you cannot claim a right to convert others. Laws that stop conversion by force, fraud, or allurement protect public order, so States can pass them.

• Do the Orissa (1967) and M.P. (1968) Acts violate Article 25(1) and (2)?
• Were the State Legislatures competent to enact these laws?

• Propagation ≠ Conversion: Article 25(1) protects sharing beliefs, not converting others.
• Public Order Limit: Religious freedom is subject to public order, morality, and health.
• State Power: Preventing forced or fraudulent conversions relates to public order → State field.

The Supreme Court upheld the validity of both Acts. It held that Article 25 protects the right to propagate religion, which means to spread or share beliefs. It does not protect a right to convert another person. A forced or induced conversion would harm the other person’s freedom of conscience.

Because coercive conversion can disturb public order, the Court said States are competent to legislate in this area. Religious freedom remains subject to public order, morality, and health.

• Article 25(1): Propagation allows communication of faith, not conversion of another person.
• Public Order: Preventing conversion by force, fraud, or allurement is a valid public-order measure.
• Legislative Competence: Such measures fall within State power.

This case sets the structure for understanding Article 25. It protects personal faith and sharing of beliefs. It does not protect attempts to convert others using pressure or inducements. The ruling also confirms that States can step in to guard public order when conversions create tension.

1. Propagation is speech; conversion is not a right.
2. Public order allows limits on coercive conversions.
3. States are competent to pass anti-conversion laws targeting force, fraud, allurement.
4. Religious freedom protects everyone’s conscience, not only the speaker’s.

Mnemonic: “ Share, Don’t Shove, State for Order”

• Share = Propagate faith.
• Don’t Shove = No right to convert by pressure.
• State for Order = States can legislate for public order.

Issue: Do anti-conversion laws violate Article 25, and can States pass them?

Rule: Article 25 allows propagation, not conversion; subject to public order, morality, health.

Application: Laws target only force, fraud, and allurement → protect public order → within State field.

Conclusion: Acts upheld; no fundamental right to convert; State competence affirmed.

Propagation

Sharing your beliefs with others.

Allurement

Offering benefits to induce conversion.

Public Order

Peace and safety in society; a limit on rights.

Conscience

A person’s own inner belief and choice.