Abrahamic Religions Exclusive, Hinduism Inclusive: Madras HC in FCRA Ruling
The Madras High Court upheld the Centre's refusal of FCRA registration to Kanzeon Public Charitable Trust, a Zen centre in Kodaikanal, holding that the conversion clause applies across all religions and that the trust should have declared itself religious.
The Madras High Court has upheld the Central government's decision to deny FCRA registration to Kanzeon Public Charitable Trust, which runs a Zen meditation centre in Kodaikanal, ruling that the trust should have disclosed itself as a religious organisation while applying. A Division Bench of Justices GR Swaminathan and MD Sumathi held that Section 12(4)(a)(ii) of the FCRA, which deals with religious conversion, applies across religions. As reported by Bar & Bench, the Bench closed its judgment with a pun on the name of the trust's founder, Rev Fr Ama Samy SJ, telling the authority to say "Illa Samy' (No Sir) to Rev.Fr.Ama Samy (which name literally translates as 'Yes')."
FCRA Conversion Clause Applies To All Religions, Says Court
The Court said the provision cuts across faiths and gave a pointed example: "A fundamentalist Hindu Organisation engaged in Ghar Wapsi cannot be registered under FCRA." It added that if foreign funds were freely allowed to facilitate religious conversions, "the sovereignty of the nation would be imperilled". What Is the FCRA Amendment Bill 2026? Key Changes and Why It Faces Opposition.
In the same passage, the Bench remarked that "radical Christian Institutions are notorious for indulging in such activities", while immediately clarifying that it was not accusing the appellant trust of having any conversion agenda.
'Salad Bowl' Remark And Kerala Reference
The Court also referred to recent friction between Christians and Muslims in Kerala and said India's plural character could be disturbed if one religious group gained ascendancy. Amit Shah Launches FCRA 2.0 Portal, e-OCI System to Digitise Key Citizen Services.
"We are a pluralist nation. Unlike USA, we are not a melting pot but a salad bowl, a beautiful metaphor credited to Justice Ruma Pal. This status quo would be upset, if one religious group gains ascendency," the Bench said.
Observations On Abrahamic Religions
Noting that the trust's founder and "moving spirit" is an ordained Christian priest, the Court invoked the saying "a leopard will not change its spots". It then observed: "Unlike Hinduism which is inclusive, the Abrahamic religions are inherently exclusive."
The Bench said devout Jews, Christians and Muslims believe theirs is the "one true and complete revelation". The judgment also recorded an argument that "native and local motifs" are sometimes appropriated by messianic religions to prepare the ground for an "eventual take over". On this, the Court said:
"It is not for us to doubt if the said claim is genuine or spurious. A strong argument is being made that the native and local motifs are appropriated by the messianic religions so that the ground is prepared for eventual take over. It is not within our province to engage in such debates. They have to be waged elsewhere."
Zen Is A Religious Tradition, Trust Was Not Upfront
The trust had argued that Zen meditation belongs to India's Dhyana tradition and that its activities should not be classified as religious. The Centre, however, maintained that the trust was engaged in religious programmes.
The Court held that Zen Buddhism is a variant of the Mahayana Buddhist school, and that Zen philosophy is of Chinese origin. It said the trust should have been open about its nature.
"The appellant need not have been so coy...One cannot keep any card up one's sleeve. This is no game of hide and seek," the Bench observed.
No Vested Right To Foreign Contributions
The Bench reiterated that there is no vested or absolute right to receive foreign contributions. Receipt of foreign contribution, it said, could at best be considered a privilege.
Indian Knowledge Systems Not Treated As Religious
The Court also drew a line between religious activity and the teaching of Indian Knowledge Systems. Organisations teaching Vedanta, the Bhagavad Gita, Upanishads, Yoga and allied subjects should ordinarily be treated as educational or cultural bodies rather than religious institutions, it said.
The appellant was represented by Advocate G Baskar, while Central Government Senior Standing Counsel G Thalaimutharasu appeared for the Union of India.
(The above story first appeared on LatestLY on Oct 07, 2026 08:19 PM IST. For more news and updates on politics, world, sports, entertainment and lifestyle, log on to our website latestly.com).
