PANAJI
Government data placed before the Goa Legislative Assembly in March 2026 shows that four cases relating to alleged illegal religious conversion or attempts were registered between 2021 and 2025. Two cases were recorded in 2022 and two in 2023, while no such cases were registered in 2021, 2024 or 2025.
The figures are significant in the context of the proposed Goa Prohibition of Unlawful Conversion of Religion Bill, 2026, which seeks to impose stringent penalties for unlawful conversion. The government's own data shows that reported cases have been limited in recent years, although the figures alone do not establish whether individual incidents were serious or whether other complaints did not result in FIRs.
The legal record in one of Goa’s most prominent alleged conversion cases provides further context. Proceedings involving Pastor Dominic and Joan D’Souza have, over several years, seen the Bombay High Court at Goa examine the material relied upon by authorities to restrict their religious activities, extern them from North Goa and pursue criminal proceedings. The court’s observations across these proceedings are instructive:
• In 2023, the High Court of Bombay at Goa held that the North Goa Collector’s order prohibiting Dominic and Joan D’Souza from carrying out religious activities at their private property violated their fundamental rights.
• The court found no complaint or material showing that the couple had used force, coercion or deception to convert anyone.
• It observed that the Collector’s order does not cite a single incident or particulars of forced conversion allegedly committed by the couple.
• Observed that their activities causing communal tension or religious conversion through allurement or fraud appeared totally baseless and were not founded on material on record.
• Observed that Dominic and Joan were within their rights to propagate their own religion and to profess it in any manner that they please, though within the bounds of law, particularly as the activities were being conducted on their private property.
• Held that Collector’s order infringed the couple’s fundamental rights under Articles 19(1), 25 and 26 of the Constitution, including freedom of speech and expression, freedom of conscience, and the right to profess, practise and propagate religion.
• In 2024, the High Court also set aside the Chief Secretary’s dismissal of the couple’s appeals relating to their externment from North Goa.
• The court found that there was no live link between the FIRs relied upon by the authorities and the subsequent externment proceedings.
• In 2025, the Court disposed of the two criminal cases against the couple after the prosecution informed the court that there was insufficient evidence to proceed in the alleged forced religious conversion.
• On September 23, the court observed that both matters deserve disposal, and quashed the FIRs.
