“Manage Crowds, Don’t Restrict Faith”: Allahabad High Court Orders Removal of Namaz Worshipers Cap in Sambhal, UP; Emphasizes State’s Duty to Protect Religious Rights

A bench of Justices Atul Sreedharan and Siddharth Nandan observed: “It is the duty of the State to ensure that every community is able to offer worship peacefully in the designated place of worship.”
High Court of Allahabad,UP
The Allahabad High Court, Uttar PradeshVroomtrapit at English Wikipedia, CC0, via Wikimedia Commons
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Key Points:

The Allahabad High Court strongly criticized the Sambhal administration’s order limiting Muslim worshippers to 20 during Ramzan, questioning why similar restrictions are not imposed on large Hindu gatherings like Maha Kumbh.
The state justified the cap citing potential law-and-order issues and private land ownership, but the Court dismissed this reasoning, stating it is the State’s duty to manage crowds and ensure peaceful worship without curbing fundamental rights.
The Court ruled in favor of the petitioner, removed the cap on worshippers, and reaffirmed Article 25, emphasizing that India’s secular fabric depends on protecting equal religious freedoms for all communities.

"If the Hindu community can gather in huge numbers to offer prayers during Maha Kumbh, why should members of the Muslim community be restricted to only 20 people in offering Namaz?" This sharp questioning by the Allahabad High Court directed at the State of Uttar Pradesh set the tone for the hearings in the case of Munazir Khan v. State of UP and 4 others.

The Dispute: A Cap On Worshippers

The case stems from a February 2026 directive passed by the Sambhal district administration, led by Superintendent of Police (SP) Krishna Kumar Bishnoi. The authorities issued an order capping the number of Muslims legally allowed to offer Namaz during the holy month of Ramzan at a local site to just 20 worshippers.

Challenging this arbitrary restriction, Munazir Khan filed a petition in the Allahabad High Court. The matter was taken up by a division bench comprising Justices Atul Sreedharan and Siddharth Nandan.

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Clash Of Arguments: Law and Order Vs. Religious Freedom

During the initial hearing on February 27, 2026, the state’s Chief Standing Council, represented by Additional Advocate General Manish Goyal and Advocate Priyanka Midha, justified the order by citing potential disruptions to law and order. They argued the cap was necessary to prevent chaotic situations arising from large gatherings during Ramzan. Furthermore, the state claimed the site in question was private property registered in the names of Mohan Singh and Bhooraj Singh, sons of Sukhi Singh.

In response, the petitioner’s counsel, Advocate Wahaj Ahmad Siddiqui, invoked the fundamental right to practice and profess religion freely. He questioned the authorities' directive to hinder peaceful worship, arguing that the site has traditionally housed a mosque and has long been used for Muslim congregations.

A bench consisting of Justice Atul Sreedharan (left) and Justice Siddharth Nandan (right) stated the order
A bench consisting of Justice Atul Sreedharan (left) and Justice Siddharth Nandan (right) stated the order.Allahabad High Court

The Court’s Reprimand

The bench did not mince words when addressing the state's law-and-order defense. In its February 27, 2026, order, the Court bluntly stated that if the Sambhal authorities could not manage a large crowd, they should resign or seek a transfer.

The Court emphasized, “It is the duty of the State to ensure that every community is able to offer worship peacefully in the designated place of worship.” It further noted that if the site is indeed a private property, as previously held, individuals have the right to perform worship there without requiring prior permission from the State. The bench clarified that such crowd restrictions can generally only be imposed in public spaces, not on private properties used for religious functions.

The Final Verdict

During the final hearing on March 16, 2026, the bench led by Justice Atul Sreedharan reviewed the petitioner's evidence and established that the land has been consistently used as a site for offering Namaz since 1995. The Court observed that while the land does not contain a traditional mosque structure, it clearly features a two-story structure on the left and two washrooms on the right, facilitating the gatherings.

Ruling in favor of the petitioner, the Court ordered the local authorities to remove any cap on the number of worshippers and directed the police to ensure law and order in the area.

Reflecting on the cultural fabric of the nation, the bench beautifully noted: “The glory of this republic of 1.4 billion of the earth's humanity lies in her resilience and strength, arising from her historical, religious, cultural and linguistic diversity, like no other nation state on this planet with every major religion, culture and varied languages having co-existed for centuries in peace, harmony and mutual respect, formalised by Article 25 of the Constitution of India after the same came into force.”

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The Essence of India’s Secular Fabric

The Allahabad High Court’s ruling in this case emphasizes the importance of India's religious diversity and secular foundation, guaranteed in the Indian Constitution .

True secularism relies on the state's commitment to protecting the constitutional right to freely profess and practice religion, ensuring no community is unfairly marginalized or restricted. By upholding Article 25, the judiciary has reaffirmed that India's unparalleled strength lies in its ability to nurture a peaceful, harmonious coexistence across all faiths, and that administrative convenience can never be used as an excuse to stifle religious freedom.

(Rh)

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