Conversion To Christianity Extinguishes Scheduled Caste Status & SC-ST Act Protection: Supreme Court Dismisses Pastor's Appeal

The Court dismissed an appeal filed by a pastor from Andhra Pradesh, who had alleged caste-based abuse and assault, and upheld the High Court’s decision quashing criminal proceedings against the accused. The Bench clarified that under Clause 3 of the Constitution (Scheduled Castes) Order, 1950, only persons professing Hinduism, Sikhism, or Buddhism can be recognised as members of Scheduled Castes, and conversion to Christianity results in an immediate loss of such status.

Justice Prashant Kumar Mishra and Justice Manmohan observed, “…it is not in dispute that the appellant was originally born into the Madiga community of Scheduled Caste. It is equally undisputed that he subsequently embraced Christianity. The submission advanced on behalf of the appellant that he continues to retain his Scheduled Caste status by birth notwithstanding such conversion cannot be accepted. When the postulates enunciated hereinabove are applied to the facts at hand, it becomes manifest that for a person to be recognised as a member of a Scheduled Caste, he must be professing the Hindu religion or such other religions as are expressly recognised under the Constitution (Scheduled Castes) Order, 1950. Once the appellant converted to Christianity, the caste status, which he earlier enjoyed as a member of the Madiga community, stood eclipsed in the eyes of law”.

“It may be observed that Christianity, by its very theological foundation, does not recognize or incorporate the institution of caste. The foundational Christian scripture, The New Testament states: There is neither Jew nor Gentile, neither slave nor free, nor is there male and female, for you are all one in Christ Jesus.8 Christianity in India exists in several denominational forms: Roman Catholics (who adhere to liturgical traditions of the Latin Church), various Protestant denominations (including the Church of South India, Baptist, Lutheran, and Pentecostal churches), and the ancient Syrian Christian communities. The aforesaid denominational distinctions arise from differences in theological interpretation, liturgical practice (the form of worship) and ecclesiastical governance (the organizational framework within the church). They do not represent any caste-based hierarchal stratifications”, the Bench further noted.

Shashibhushan P. Adgaonkar, AOR appeared for the appellant and Senior Advocates Dvss Somayajulu, and Nachiketa Joshi appeared for the respondent.

The matter pertained to the allegations by the appellant, who belonged to the Madiga community by birth but had been working as a Christian pastor for nearly a decade. He claimed that he was assaulted, abused by caste name, and threatened by members of another community while conducting prayer meetings. An FIR was registered under provisions of the SC/ST Act as well as Sections 341, 323, and 506 of the IPC.

However, the High Court quashed the proceedings, holding that the appellant, being a practising Christian, could not invoke the SC/ST Act, this finding was challenged before the Supreme Court.

Affirming the High Court’s reasoning, the Court emphasised that the expression “professes” in the 1950 Order implies an open declaration and practice of a religion.

“A careful perusal of Clause 3 of Constitution (Scheduled Castes) Order, 1950 reveals that the term ‘professes’ is of crucial significance. The clause excludes any person who professes a religion different from Hindu, Sikh or Buddhist from being deemed a member of a Scheduled Caste. It is, therefore, necessary to examine what constitutes to professing a religion”, the Bench noted.

It noted that the appellant had been actively serving as a pastor, conducting regular Sunday prayers, and thus clearly professed Christianity. In such circumstances, the Court held that his earlier caste identity stood legally extinguished, and he could not claim statutory protections reserved for Scheduled Castes. The Court also rejected reliance on a State Government Order extending certain benefits to SC converts, observing that such executive instructions cannot override the constitutional scheme or extend to statutory protections under central laws.

“…it is not the case of the appellant that at any stage, he had reconverted from Christianity to his original religion or has been accepted back into the fold of the Madiga community. On the contrary, the evidence on record unmistakably establishes that the appellant continues to profess Christianity and has been functioning as a Pastor for more than a decade, conducting regular Sunday prayer meetings in different houses of the village. It is also an admitted position that at the time of the alleged incident, the appellant was conducting prayer meeting as a Pastor at the house of one Doma Koti Reddy. These concurrent facts leave no room for doubt that the appellant continues to remain a Christian on the date of the occurrence”, the Bench noted.

The appellant placed reliance upon G.O. Ms No.341, Social Welfare Department, Government of Andhra Pradesh, dated 30.08.1977, which extends certain concessions granted to Scheduled Castes (Hindus) by the State Government to Scheduled Caste converts to Christianity and Buddhism. It was contended that considering the GO, the appellant ought to be recognized as a member of the Scheduled Caste for the purposes of invoking the provisions of the SC/ST Act.

However, the Bench categorically noted, “The Government Order itself draws a clear and categorical distinction between statutory and non-statutory benefits. Clause 2 of the Government Order states that only “non-statutory concessions’’ are being extended to Scheduled Caste converts to Christianity and Buddhism. These non-statutory concessions include economic support and similar welfare schemes which do not flow from statutory mandate”.

Crucially, the Court laid down detailed principles governing claims of Scheduled Caste status after religious conversion. It held that conversion to a religion not specified in the Presidential Order results in complete loss of SC status, and such persons cannot claim any statutory benefits or protections based on that status. The Court further clarified that reconversion claims must meet strict requirements, including proof of return to the original religion and acceptance by the community.

On reliance based on the caste certificate, the Bench noted, “As far as the contention of the learned counsel for the appellant placing reliance on the caste certificate is concerned, we are of the view that mere possession of the certificate will not be of any benefit to the appellant. The said caste certificate is mandatorily required to be in consonance with the Constitution (Scheduled Castes) Order, 1950...”.

On the criminal allegations, the Court also found that the charges under the IPC were not supported by sufficient evidence. It noted inconsistencies in witness statements, lack of corroboration, and absence of specific allegations against the accused. Applying the settled principles on quashing of criminal proceedings, the Court held that continuing the trial would amount to abuse of process.

Accordingly, the Supreme Court dismissed the appeal and upheld the quashing of proceedings, reiterating that statutory protections under the SC/ST Act are strictly contingent upon fulfilling the constitutional definition of Scheduled Caste status.

Cause Title: Chinthada Anand v. State Of Andhra Pradesh And Others [Neutral Citation: 2026 INSC 283]

Appearances:

Appellant: Shashibhushan P. Adgaonkar, AOR.

Respondent: Dvss Somayajulu, Sr. Adv., Nachiketa Joshi, Sr. Adv., Santosh Kumar, Tadimalla Bhaskar Gawtham, Aditya Sharma, AOR, Alabhya Dhamija, Aditi, Gautam Singh, Aditi Tripathi, Sai Shashank, Vikash Shukla, Pankaj Singhal, Chanakya, Mohiteshwari Prasad, Advocates.

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