Preaching needs prior permission even when no one is converted, the Madras High Court has held, upholding the cancellation of an American citizen’s OCI registration under the Centre’s 2021 notification.
Chennai: The OCI registration of an American citizen, whom the authorities accused of conducting religious meetings and preaching in Tamil Nadu and Andhra Pradesh without permission, was rightly cancelled, the Madras High Court held on October 26, 2026, dismissing his writ petition and ruling that preaching one’s religion requires prior official permission even where no conversion takes place [John Daniel v. Union of India and Others].
Justice D. Bharatha Chakravarthy pronounced the order after reserving judgment on September 30, 2026. Senior Advocate R. Shanmuga Sundaram, assisted by Advocate A.G. Shakeenaa, appeared for the petitioner, and Senior Panel Counsel Dr. S. Padma appeared for the Union.
Preaching as missionary activity
Spreading religious messages by preaching is missionary activity, the Court held, whether or not any conversion follows, and prior permission is needed for it. On what happens when a cardholder acts without that permission, it said:
if the petitioner carries on missionary activities without permission, the same violates Section 7B of the Act
The material on record, the Court found, showed that the petitioner took part in religious congregations and public meetings in both States, and it recorded that he is a professional missionary who spreads the word of God in relation to his religion. The contention that he travelled only for family reasons was not accepted. The Court also held that the principles of natural justice are not a straight-jacket formula and depend on the facts, and added that the remedy under Article 226 of the Constitution is an equitable remedy.
The cancellation and the challenge
Overseas Citizen of India registration had been granted to the petitioner in February 2015. After a show-cause process, the Foreigners Regional Registration Officer (FRRO), Chennai, cancelled it by an office memorandum dated September 4, 2026. The authorities alleged that he held religious meetings and preached in interior villages without permission, encouraged conversions to Christianity and led an organisation that they described as functioning like a cult. These are the authorities’ allegations.
He denied them. His visits to India, he said, were mainly to see his 92-year-old mother and relatives, and he had never done missionary work, promoted conversions or held any office in the organisation. To make its case, the Union relied on posters, advertisements and internet material from 2017 to 2019 about religious gatherings, among them meetings in Tenali in Andhra Pradesh and gatherings at Stuartpuram village.
What the statute and notification say
Section 7A of the Citizenship Act, 1955 lets the Central Government register a person as an Overseas Citizen of India cardholder, and Section 7D provides for cancellation of registration in specified situations. Under Section 7B and the notification dated March 4, 2021 (S.O. 1050(E)), a cardholder gets a multiple-entry lifelong visa but must obtain special permission from the competent authority before undertaking missionary, public, mountaineering or journalistic activities.
What the petitioner is left with
The writ petition was dismissed with no order as to costs. The petitioner remains free to apply for a regular visa to visit his mother, and the Court said he can conduct religious meetings and carry out religious activities in India only after obtaining the requisite official permission.
Why the order matters
The order reads the permission requirement of the 2021 notification as covering preaching itself, not only conversion, so an OCI cardholder who addresses religious gatherings without the competent authority’s permission risks cancellation of registration. On the material produced before the Court, the petitioner’s denial of the allegations was not accepted.
Case Title: John Daniel v. Union of India and Others [W.P. No. 37464 of 2026]
Bench: Justice D. Bharatha Chakravarthy, Madras High Court
Date of Order: October 26, 2026 (reserved on September 30, 2026)
Appearances: Senior Advocate R. Shanmuga Sundaram with Advocate A.G. Shakeenaa for the petitioner; Senior Panel Counsel Dr. S. Padma for the Union.