Court case(1977) 1 SCC 677

The Madhya Pradesh Dharma Swatantrya Adhiniyam, 1968 and the Orissa Freedom of Religion Act, 1967 made it an offence to convert, or attempt to convert, any person by force, fraud or allurement (inducement), and required conversions to be reported to the District Magistrate. Rev. Stanislaus, a Catholic priest prosecuted in Madhya Pradesh, challenged the Act. The Madhya Pradesh High Court upheld it, but the Orissa High Court struck down the Orissa Act as beyond State competence and violative of Article 25. Both matters came to the Supreme Court.

Ray CJ, for a unanimous Constitution Bench, held that the word "propagate" means to transmit or spread one's religion by an exposition of its tenets; it does not confer a right to convert another person to one's own religion. Article 25(1) guarantees freedom of conscience to every citizen, not merely to the followers of one religion; if a person purposely undertakes to convert another, as distinguished from trying to transmit the tenets of his religion, it would impinge on the freedom of conscience of that other. Conversion by force, fraud or allurement affects the community and can disturb public order, so the Acts were within Entry 1 of the State List. Both Acts were upheld; the Orissa High Court's judgment was reversed.