The Allahabad High Court awarded ₹25 lakh compensation to two adult sisters illegally confined after converting to Islam. The court held that parental disapproval and pending criminal investigations cannot justify detention of adult women exercising their constitutional right to choose faith and residence. Reaffirming Articles 21 and 19(1)(d), the court ruled that neither family objection nor police inaction can override personal liberty, ordering compensation from the state for failing to protect the women's fundamental rights.

This judgment sits at the intersection of three constitutional guarantees: Article 21 (right to life and personal liberty), Article 19(1)(d) (freedom of movement), and Article 25 (freedom of conscience and religion). The court applied the settled principle that an adult's decision about faith, residence, and companionship is within their constitutionally protected zone of autonomy — a principle traced from Maneka Gandhi v. Union of India (1978), which expanded Article 21 beyond mere physical detention to include meaningful, reasoned protection of liberty.

The critical doctrinal move here is on state liability for compensation. Ordinarily, sovereign immunity shields the state from tortious liability. However, since Nilabati Behera v. State of Orissa (1993) and Rudal Shah v. State of Bihar (1983), the Supreme Court established that where fundamental rights are violated, sovereign immunity is inapplicable and the state must pay constitutional compensation under Article 32/226 — a public law remedy distinct from private law damages. The Allahabad HC applied this same logic: state failure to prevent illegal confinement triggers direct compensatory liability.

For CLAT PG, the examiner will test: (1) whether parental or familial authority can override an adult's Article 21 rights, (2) the non-availability of sovereign immunity for fundamental rights violations, and (3) the distinction between private law tort damages and public law constitutional compensation. The conversion-plus-detention scenario is a classic habeas corpus fact pattern the court regularly encounters.