Case Summary

A 15-year-old Hindu girl from Phaphamau in Prayagraj was lured with the promise of marriage by Mohammad Irfan, a Muslim man from Bahraich district. Thereafter, he pressured her to convert to Islam and repeatedly threatened to kill her and destroy her family's life when she refused. According to the FIR lodged by the victim's mother, Janaklali Modanwal, the accused groomed the minor over a period of time and subjected her to continuous pressure to embrace Islam. The complainant stated that her shop was located around 100 metres from a biryani shop operated by Sartaj Ali(another accused), where Mohammad Irfan also worked, and that the accused used this proximity to trap the minor into his influence. She further stated that the accused had devised a plan to facilitate the girl's religious conversion, used multiple Instagram accounts to contact and manipulate her, and also issued threats in the presence of the victim's younger sister. The FIR further named Sartaj Ali, Irfan's younger brother, and his parents as being involved in the incident. When the victim's mother confronted Mohammad Irfan and questioned why he was ruining her daughter's life, he abused her and threatened her. The complainant also expressed apprehension that pressure on her daughter to convert to Islam would continue. Based on the complaint, a case was registered at Phaphamau Police Station under Sections 352 and 351(2) of the Bharatiya Nyaya Sanhita (BNS) and Sections 3 and 5(1) of the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021. Eventually, on 17 July 2026, Phaphamau Police arrested Mohammad Irfan and Sartaj Ali, aged 20 and 25, near the road leading from Nav Jeevan Hospital to Bela Kachhar. Both accused were originally residents of Fakharpur, Bahraich, and were running a biryani shop at Shantipuram Chauraha, Phaphamau. Police initiated further legal proceedings in the matter.

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Why it is Hate Crime ?

This case has been added to the tracker under the primary category of Predatory Proselytisation & with the sub-category of Harassment, threats, coercion for conversion Harassment covers a wide range of behaviours of an offensive nature. It is commonly understood as behaviour that demeans, humiliates, and intimidates a person, including threats and coercion. Harassment and threats, in this case, find their root on discriminatory grounds which has the effect of nullifying a person’s rights or infringing upon his freedom to exercise his right specifically owing to the victim’s religious identity. Verbal and physical threats and psychological or physical harassment are often used against Hindu victims because they choose to practice their professed religion. Religious harassment also includes forced and involuntary conversions by harassment, threats or coercion. Coercion includes intimidatory tactics like force-feeding a Hindu victim beef to convert to another religion, forceful circumcision etc. In several cases documented, non-Hindu perpetrators or those who harbour specific animosity towards Hinduism, harass victims simply based on their religious identity. Such cases often also include harassment to ensure the Hindu victim abandons his/her professed religion and adopts the religion of the perpetrator. Such cases where Hindu victims are harassed to convert to the perpetrator’s religion are rooted in animosity towards the victim’s religious identity and are therefore documented as religiously motivated hate crimes. The second sub-category within it is Proselytisation by grooming, brainwashing, manipulation or subtle indoctrination. The tertiary category selected under this is Family claims grooming and conversion of a minor. Religious brainwashing essentially means the often subtle and forcible indoctrination to induce someone to give up their religious beliefs to accept contrasting regimented ideas. Religious grooming or brainwashing also involves propaganda and manipulation. It involves the systematic effort, driven by religious malice and indoctrination, to persuade “non-believers’ to accept allegiance, command, or doctrine to and of a contrasting faith. Cases of such grooming or brainwashing are far more nuanced than direct threats, coercion, inducement and violence. In such cases, it is often seen that there is repeated, subtle and continual manipulation of the victim to induce disaffection towards their own faith and acceptance of the contrasting faith of the perpetrator. While subtle indoctrination is widely acknowledged as predatory, an element which is often understated in such conversions or the attempts of such conversion is the role of loyalty and trust which might develop between the perpetrator and the victim. Fiduciary relationships are often abused to affect such religious conversion. For example, an educator transmitting religious doctrine of a competing faith to a Hindu student. The Hindu student is likely to accept what the teacher is transmitting owing to existence of the fiduciary relationship. The exploitation of the fiduciary relationship to religiously indoctrinate victims would also be included in this category. Since the underlying animosity towards the victim’s faith forms the basis of predatory proselytization, such cases are considered religiously motivated hate crimes. This incident has been added to the tracker because it exhibited multiple elements that indicated a sustained attempt to secure the religious conversion of a minor Hindu girl. Firstly, the development of an emotional relationship through the promise of marriage served as the foundation for influencing the victim to abandon her professed faith. The relationship became a vehicle for grooming, where trust, emotional dependence, and personal attachment were exploited to facilitate religious conversion. Such cases extend beyond the realm of an ordinary personal relationship because the emotional bond is used to reshape the victim's religious identity. Secondly, the victim's religious conversion was pursued through intimidation and sustained psychological pressure rather than through the exercise of free and informed choice. The use of threats against both the victim and her family demonstrated that coercive methods were employed to compel the victim to renounce her professed faith and adopt that of the perpetrators. Such conduct reflected a pattern of religious targeting in which intimidation was used to erode the victim's ability to freely practise and retain her religious identity. Thirdly, the victim being a minor was a significant factor in assessing the nature of the incident. Since the victim was a minor, she was inherently more vulnerable to emotional manipulation, grooming, and coercion than an adult. Moreover, the element of free, informed, and legally valid consent was absent from the outset. Minors, owing to their age and emotional immaturity, are particularly vulnerable to grooming, manipulation, and coercion, and are often unable to fully comprehend the long-term implications of changing their religion. In this case, the victim's vulnerability was exploited through sustained emotional influence, intimidation, and pressure to abandon her professed faith and embrace Islam. Since this incident exemplified the use of grooming, coercion, and manipulation to facilitate the religious conversion of a minor Hindu girl, it constituted a religiously motivated act of predatory proselytisation and has therefore been documented in the hate crime database.