The Allahabad High Court released two adult daughters confined by their father for approximately four years because they converted to Islam. The court held the confinement constituted an exceptionally grave and egregious violation of Articles 21 and 25 of the Constitution. It directed payment of ₹25 lakh as compensation for the deprivation of personal liberty and freedom of conscience. The ruling affirms that no family member can override an adult's fundamental right to choose their religion.

This ruling sits at the intersection of three distinct constitutional guarantees: Article 21 (right to life and personal liberty), Article 25 (freedom of conscience and free profession, practice and propagation of religion), and the judicially evolved doctrine of constitutional tort compensation.

Article 25 guarantees every person the freedom of conscience and the right to freely profess, practice and propagate religion. Crucially, it protects individual choice against both State and private coercion. The Supreme Court in Shafin Jahan v. Asokan K.M. (2018) — the Hadiya case — established that an adult's right to choose their faith and their life partner falls squarely within the personal liberty guarantee of Article 21. The court held that neither the State nor the family can substitute their judgment for that of a competent adult.

The compensation dimension traces to Rudul Shah v. State of Bihar (1983), where the Supreme Court first awarded monetary compensation under writ jurisdiction for violation of fundamental rights, moving beyond mere release orders. Sebastian M. Hongray (1984) and Bhim Singh v. State of J&K (1985) consolidated this principle into the doctrine of constitutional tort: the State — and through High Court orders, private actors whose conduct is judicially reviewed — can be compelled to pay for fundamental rights violations.

For CLAT PG, the examiner will likely present this ruling as a passage and test: (a) which Articles were violated, (b) whether Article 25 can be invoked against a private individual, and (c) the legal basis for awarding compensation in writ proceedings. The answer to (b) is nuanced — the court's jurisdiction operates through the writ against state inaction in protecting the right, not by making Article 25 directly enforceable against a private party.