MP sees 90% acquittal rate in ‘Love Jihad’ cases:283 cases filed in 5 years, only 7 end in convictions; experts outline why most trials collapse in court

Cases of alleged ‘love jihad’ are once again making headlines in Madhya Pradesh. Four cases have been reported in the last fifteen days. Two are from Indore, one from Bhopal, and one from Khandwa. In one of the Indore cases, a complaint by a young woman led to a case being registered against the accused, Irfan Ali. In the other, the young woman refused to lodge an FIR. Meanwhile, in Bhopal, following the suspicious death of a model, a case has been registered against her Muslim boyfriend, Qasim, under sections related to alleged ‘love jihad’, i.e., the Religious Freedom Act 2021. In Khandwa, a case has been registered against two youths based on a woman’s complaint. In the next stage of the process, police will investigate these matters and present a challan in court within the mandated time. A notable pattern in ‘love jihad’ cases is that despite the political and social uproar they create, the narrative often changes once they reach the courts. Data from the last five years shows that out of 283 cases, only 7 have resulted in convictions. Bhaskar examined similar cases in which the accused were acquitted. The question was: why? Legal experts were consulted. Here is the report. Understand all three cases sequentially Case 1: Model’s death and ‘Love Jihad’ case against live-in partnerOn 11 November, Bhopal model Khushboo Ahirwar died under suspicious circumstances. She had been in a live-in relationship with a man named Qasim. The preliminary post-mortem report cited pregnancy-related complications as the cause of death. However, Khushboo’s mother filed a case against Qasim, accusing him of murder and ‘love jihad’. She alleged that Qasim trapped her daughter by hiding his identity and pressuring her to convert. Police arrested Qasim and registered a case under the Religious Freedom Act. During interrogation, Qasim claimed he and Khushboo had been together for two years, the child was his, and they were planning to marry. Case 2: Rape, blackmail, and pressure for religious conversionAnother serious case surfaced in Indore on 10–11 November. A woman from Rajasthan filed an FIR against Irfan Ali, also known as Happy Punjabi, under charges of rape, blackmail, assault, and the Religious Freedom Act. She alleged that Irfan raped her repeatedly and also forced his friend to rape her. The woman claimed she was forcibly made to eat beef and coerced into converting. She had also undergone an abortion. Irfan Ali is a notorious criminal from Dewas, with 16 criminal cases registered against him, and he has been externed from the district. Case 3: Gym trainer beaten; woman refuses to file FIRIn another incident, Bajrang Dal workers in Indore beat a gym trainer named Shadab on suspicion of ‘love jihad’ and handed him over to the police. They alleged that despite being married and the father of two children, he lured young women at the gym by concealing his identity. However, when police contacted the woman involved, she refused to file any FIR. These three cases show different patterns—one involves a family’s allegation after a death, another involves serious exploitation, and the third involves action by an organisation but no complaint from the woman herself. Accused acquitted in 90 percent of cases In Madhya Pradesh, the number of convictions is very low compared to the number of ‘love jihad’ cases filed. Assembly documents confirm this. The government stated that from January 2020 to 15 July 2025, a total of 283 alleged ‘love jihad’ cases were registered under the Madhya Pradesh Religious Freedom Act, 2021. Of these, 74 were registered in Indore and 33 in Bhopal, accounting for roughly 40 percent of the total. Khandwa and Ujjain reported 12 cases each, and Chhatarpur reported 11. Out of the 283 cases, 197 are still pending. Only 86 cases have reached judgement. Of those, 50 resulted in acquittal, only 7 in conviction, and the rest were dismissed or settled. Now, why do ‘love jihad’ cases collapse in court? To answer this, two older cases were analysed to understand why they weakened during legal proceedings. Case 1: When the victim and witnesses recanted Incident: On 26 August 2021, a Class 12 student in the Mundi police station area of Khandwa accused Salman Khan of pressuring her to convert and marry him. She said he harassed her and threatened to kill her if she did not change her religion. Police filed a case under multiple IPC sections and the Religious Freedom Act. Court outcome: The victim, her mother, and her brother were the main witnesses. During the hearing, all three withdrew their statements. The girl said she knew Salman but he had not threatened or molested her, and that she had filed the complaint under police pressure. Her mother and brother also did not support the prosecution. Case 2: When a wife filed a ‘Love Jihad’ case against her Hindu husband Incident: On 16 December 2023, in Jirapur, Rajgarh, a woman filed a ‘love jihad’ case against her husband, Dilip Khatik. She claimed that although they married according to Hindu rituals in 2004, he had later converted under someone’s influence and was forcing her and their son to convert, offer namaz, and observe roza. Police action: Police registered an FIR under the Religious Freedom Act and arrested Dilip. Court status: Dilip received bail after two weeks. Months later, the police still had not filed a chargesheet. Dilip claimed his wife filed a false case to hide her alleged affairs. The case appeared weak from the investigation stage itself. To understand why many such cases fail in court, senior lawyers from the Madhya Pradesh High Court and district courts, as well as a former IPS officer, were consulted. They cited six main reasons: 1. Witnesses turning hostile This is the most common reason. In many cases, the victim or her family withdraw their statements, saying the complaint was filed in anger, under social pressure, or due to police influence. When the main witness turns hostile, the case collapses. Senior Advocate Dheeraj Tiwari adds that some cases are filed based on suspicion due to pressure from organisations, without concrete evidence. 2. Lack of concrete evidence To prove fraud, force, or coercion, strong evidence is needed. In most cases, police fail to produce digital evidence such as chats, call records, videos, or documents that show intent. 3. Weak police investigation Investigators often fail to collect technical evidence such as CDRs, mobile forensics, or social media analysis. Poor investigation and weak chargesheets help the defence. 4. FIRs filed under social or political pressure Many cases arise due to pressure from families or organisations rather than proven wrongdoing. Investigations later find the relationship was consensual, making the case weak in law. 5. Consent of adults If both individuals are adults and the relationship is consensual, it is not a crime. Article 21 of the Constitution gives adults the right to choose their partner. In such cases, the Religious Freedom Act does not apply. Retired IPS officer N. K. Tripathi says adults are free to live together, but fraud, deception, or forced marriage remains a crime. 6. No clear evidence of religious conversion The law requires proof of pressure or deceit for conversion. In most cases, there is no formal conversion process or direct evidence of coercion. Advocate Wahid Khan says sometimes the relationship is consensual, but families or organisations push for a case. Such cases collapse in court, and judges allow adult couples to live together.