Chhattisgarh Churches Put Up ‘Enter at Own Risk’ Boards as Freedom of Religion Act, 2026 Takes Effect

The news

Raipur/Dhamtari. Churches in Dhamtari, Chhattisgarh, have put up noticeboards telling non-Christians that they enter at their own risk, a month after the Chhattisgarh Freedom of Religion Act, 2026 was notified in August, The Hindu reports on its front page. The board in Hindi outside the 116-year-old Sunderganj Mennonite Church reads: “In accordance with church management rules, entry into the church for worship is restricted to Christians. Others who enter voluntarily do so at their own risk.” A board outside the Church of God in the same city says: “Worship here is exclusively for Christians; if you are not legally a Christian, you will be held personally responsible.” Diamond Philus, general secretary of the Dhamtari District Christian Forum, said they were put up “primarily as a precautionary measure to avoid action” under the new law, which Ministers in the BJP government say is aimed at curbing religious conversions. An anti-conversion law is a State statute that prohibits changing a person’s religion by force, fraud or inducement and usually requires advance notice to the district authorities. According to Mr. Philus, the Chhattisgarh law requires anyone seeking to change their religion to inform the district administration 60 days in advance; he called its provisions “draconian” and alleged that they leave room for anyone to be framed. The forum claims that more than 1,000 people have submitted self-declaration forms at the District Collectorate stating that they attend religious meetings at churches or prayer halls “voluntarily and at their own risk”. The form states that attendance is based on personal faith and freedom of conscience, and requires the applicant to confirm that there has been no force, threat, undue influence, inducement, fraud or deception. Mr. Philus said a second reason for the boards was the disruption of prayer meetings by right-wing groups; such disruptions, and disputes over the last rites of the deceased, have often been reported in Dhamtari and elsewhere in the State. He alleged that at a meeting at the District Collectorate on September 15, right-wing groups, whose presence the forum had not been told of, demanded that people not be allowed inside churches until they had converted, and officials supported them. The paper carries no response from the government to these allegations. The syllabus link is GS2 on fundamental rights, the secular character of the Constitution and the protection of vulnerable minorities, and GS1 on communalism and secularism.

Static syllabus linkage

1. Article 25 protects propagation of religion, not a right to convert others. Article 25(1) guarantees to all persons, not only citizens, freedom of conscience and the right freely to profess, practise and propagate religion, subject to public order, morality, health and the other provisions of Part III. Article 25(2) lets the State regulate any economic, financial, political or other secular activity associated with religious practice and make laws for social welfare and reform. In Rev. Stainislaus v. State of Madhya Pradesh (1977), a five-judge Constitution Bench upheld the Madhya Pradesh Dharma Swatantrya Adhiniyam, 1968 and the Orissa Freedom of Religion Act, 1967. It held that “propagate” means to transmit or spread one’s religion by an exposition of its tenets, not a fundamental right to convert another person, and that conversion by force, fraud or allurement impinges on the freedom of conscience guaranteed to all. The Court also held that such laws fall within the State’s power over public order, Entry 1 of the State List.
2. Anti-conversion laws are State laws with a long lineage and a common template. Odisha (1967) and Madhya Pradesh (1968) enacted the first freedom of religion laws, followed by Arunachal Pradesh (1978), and later Gujarat (2003), Himachal Pradesh, Jharkhand, Uttarakhand, Uttar Pradesh (2021) and Karnataka (2022), among others. Chhattisgarh, carved out of Madhya Pradesh in 2000, inherited the 1968 Madhya Pradesh law before enacting its own. The common template prohibits conversion by force, fraud, allurement or inducement, requires prior intimation to the District Magistrate, and prescribes higher punishment where the person converted is a minor, a woman or a member of a Scheduled Caste or Scheduled Tribe. Several of the newer laws also place the burden of proving that a conversion was lawful on the person who caused it. Parliament has never enacted a national anti-conversion law.
3. The right to choose one’s faith is also part of privacy and personal liberty under Article 21. In Justice K.S. Puttaswamy v. Union of India (2017), a nine-judge Bench held that privacy is a fundamental right and that it includes decisional autonomy over intimate personal choices. In Shafin Jahan v. Asokan K.M. (2018), the Hadiya case, the Supreme Court restored the marriage of an adult woman who had converted to Islam, holding that the right to marry a person of one’s choice and to choose one’s faith is integral to Article 21 and that the State and courts cannot sit in judgment on such adult choices. These rulings sit in tension with prior-intimation regimes, because a person must disclose a private decision of faith to the district administration and wait. Petitions challenging several State anti-conversion laws on these grounds have been pending before the Supreme Court.
4. Article 26 gives religious denominations autonomy to manage their own affairs in matters of religion. Article 26 guarantees every religious denomination, or section of it, the right to establish and maintain institutions for religious and charitable purposes, to manage its own affairs in matters of religion, to own and acquire property and to administer it in accordance with law. The phrase “matters of religion” has been read by the Supreme Court to include rituals and forms of worship that are integral to the faith. A church restricting worship to its own members under its management rules is therefore an exercise of denominational autonomy. It is the mirror image of Article 25(2)(b), which lets the State throw open Hindu religious institutions of a public character to all classes and sections of Hindus.

Why UPSC loves this

1. GS2 and GS1 repeatedly test the limits of religious freedom. Mains questions have asked candidates to examine the scope of freedom of religion under Articles 25 to 28 and to discuss secularism in the Indian context as distinct from the Western model. Anti-conversion laws are the sharpest live test of both, because they involve the State deciding whether a change of faith is genuine. The Chhattisgarh story adds a new angle: a minority institution restricting its own doors in response to a law.
2. Prelims asks which Article, which case and which List. UPSC has asked about the rights under Article 25 and Article 26 and about which rights are available to all persons as against citizens alone. The Stainislaus holding on “propagate”, the placing of anti-conversion laws under public order in the State List, and the Puttaswamy and Hadiya line on autonomy are the facts most likely to be tested.
3. Essay and ethics papers use such stories as case material. Topics on tolerance, pluralism and the relationship between State and religion recur in the Essay paper. The September 15 meeting at the Collectorate, where officials allegedly sided with one group, is also a classic GS4 case on impartiality and the neutrality of the civil servant.

Analysis

1. The boards show that the law is shaping behaviour well beyond actual conversions. Nobody in the report has been prosecuted, yet a 116-year-old church has changed its entry rules and more than 1,000 people have filed declarations that they were not induced. This is the chilling effect that lawyers warn about: when a statute is broad and the consequences are criminal, people over-comply to stay safe. The practical freedom to attend a place of worship out of curiosity, friendship or grief has shrunk without any court or legislature deciding that it should. A law’s constitutionality is tested on its text, but its real reach is measured by what ordinary people stop doing, and on that test the effect in Dhamtari is already large. The counter-view is that the boards are a choice of the churches themselves and that nothing in the law, as reported, bars a non-Christian from entering a church.
2. The self-declaration form is an inversion of the presumption of innocence. The form asks a worshipper to certify that there has been no force, fraud, inducement or deception, and that none has come to his or her notice. In effect, the ordinary act of attending prayer is being treated as something that needs a clean chit from the Collectorate. A citizen should not have to pre-clear lawful conduct with the State, and a private forum should not have to organise such paperwork to protect its members. The form also creates a record of who attends which church, which is exactly the kind of data that Puttaswamy warns can be misused. Its only virtue is protective: if a complaint is filed later, the worshipper has contemporaneous evidence of voluntariness.
3. Stainislaus settled the power to legislate, not the proportionality of each law. Supporters of the Chhattisgarh law will rely on Stainislaus, which upheld the principle of prohibiting forced or induced conversion. But that judgment examined laws of the 1960s with a narrower design and was decided before Puttaswamy brought proportionality and decisional autonomy into rights analysis. A 60-day waiting period and prior disclosure to the district administration are procedural burdens that a court today would weigh against their purpose. The pending challenges in the Supreme Court are likely to turn on this distinction: the State may prohibit coercion, but must show that each procedural hurdle is necessary and the least restrictive means. Stainislaus is the floor of the argument, not its end.
4. The district administration, not the statute, is where the conflict is really decided. The disputes that Mr. Philus describes, disrupted prayer meetings and quarrels over last rites, are law-and-order matters that fall to the Collector and the Superintendent of Police. If officials at the September 15 meeting endorsed a demand that non-converts be barred from churches, they went beyond anything the law requires and took a side in a religious dispute. The paper carries only the forum’s account, and the administration’s version is not reported, so the allegation must be treated as unverified. Either way, the episode shows that the neutrality of the district officer is the real safeguard for minorities under any conversion law. A law that is applied evenly may be defensible; one that is used by one group against another becomes an instrument of pressure.
5. The concern about conversion is real, and the answer is evidence rather than suspicion. The State’s case is that conversions in tribal and poor areas are sometimes procured through inducements such as money, schooling or healthcare, and that vulnerable people need protection. That concern has been raised for decades and is not illegitimate. But a regime that treats all attendance at church as potential conversion does not target inducement; it targets presence. Better tools exist: prosecuting actual cases of fraud with evidence, ensuring that tribal areas have public schools and hospitals so that no private agency can use them as leverage, and giving the burden of proof its ordinary place. Protection that makes a whole community feel under watch fails the constitutional promise of fraternity.

Administrator's brainstorm