Background

Why India distrusts foreign missionaries.

The distrust is not new. It comes from an old accusation, that missionaries convert people with money and pressure, and it became law in several states. It is worth seeing where it comes from, what the courts decided and what the numbers say.

Illustration: a bound report, spectacles and a pile of papers on a desk in an Indian government office

India in Data and Maps3 min readSeptember 29, 2026

In short: supporters of the conversion laws say that missionaries, especially foreign ones, use material help and foreign money to convert poor people, which they say threatens public order. The churches answer that the Constitution guarantees the right to profess and propagate religion. The courts have sided with each view on different points.

1956: the first official inquiry

In 1954, the government of Madhya Pradesh set up a committee to examine the accusations against Christian missionaries. It was chaired by M. B. Niyogi, a former Chief Justice of the Nagpur High Court. According to the report's own description, the committee contacted 11,360 people, heard from residents of about 700 villages and received 375 written statements.

The report, published in 1956, recommended that missionaries whose primary object is proselytisation be asked to withdraw and that the large influx of foreign missionaries be checked. According to the Wikipedia summary, its recommendations influenced state bills against forcible conversions. The report was criticised by theologians, Christians and politicians, and the Roman Catholic Church withdrew its cooperation with the inquiry.

1977: the Supreme Court and the word “propagate”

On January 17, 1977, in Rev. Stainislaus v. State of Madhya Pradesh, the Supreme Court held that Article 25 of the Constitution protects the right to transmit and spread one's own religion, but not the right to convert another person. The Court reasoned that forced or induced conversion infringes the freedom of conscience of the person converted, and that states may punish conversions made by force, fraud or “allurement”. With that ruling, the laws of Odisha (1967) and Madhya Pradesh (1968) were upheld.

Money from abroad: the FCRA

The second axis is funding. The Foreign Contribution (Regulation) Act, the FCRA, requires registration or government permission to receive money from abroad. According to the official FCRA portal, compiled by PRS Legislative Research, in July 2026 there were 14,449 active licences and 22,498 cancelled ones. In April 2024, the Indian press counted 20,701 cancelled since 1976. The full picture, with the rules and the 2026 amendment bill, is in What Is the FCRA and Why It Affects Churches and Missions.

The other side: what the courts and the census say

On January 10, 2019, the Delhi High Court set aside the cancellation of the OCI card (overseas citizenship of Indian origin) of a doctor accused of hiding that he was doing evangelical missionary work. Justice Vibhu Bakhru wrote that Article 25 “is not restricted to the citizens of this country but is available to all persons,” and found that the assumption that missionary activity is illegal was fundamentally flawed.

The census also helps measure the alleged “wave of conversions”. According to India's Registrar General, in 2011 Christians numbered 2.78 crore (27.8 million), 2.3% of the population, and the Christian share showed no significant change from 2001. The 2011 census is the latest; newer data has not been released. The numbers do not say whether isolated cases of irregular conversion occurred, but they show that the Christian share of the country did not grow.