ON MARCH 24, the Supreme Court of India held that a person who has converted to Christianity cannot be recognised as a member of a Scheduled Caste. Upholding a decision by the Andhra Pradesh High Court, a two-judge bench of Justices Prashant Kumar Mishra and Manmohan clarified that Scheduled Caste status is legally contingent on professing Hinduism or any other religion explicitly recognised under the Constitution (Scheduled Castes) Order, 1950 (‘1950 Order’) and statutory protections tied to Scheduled Caste status cannot survive a religious identity that the law does not recognise within that category.
The tale of an assault
In December 2020, a Christian pastor Chinthada Anand, who belonged to the Madiga community, a Scheduled Caste, received abusive and threatening phone calls laced with caste-based slurs, allegedly in response to his religious activities and growing presence as a pastor.
On January 3, while leading a prayer gathering at a villager’s home, Anand was allegedly called outside by one of the accused, physically assaulted, abused by caste name, and warned against continuing such meetings. A few weeks later, Anand claimed that while returning home after prayers, he was stopped by a group that included the accused and several others, dragged, beaten, and publicly humiliated with caste-based abuse. He alleged that his belongings were snatched and the group passed threats of death and kidnapping against him and his family.
In December 2020, a Christian pastor Chinthada Anand, who belonged to the Madiga community, a Scheduled Caste, received abusive and threatening phone calls laced with caste-based slurs.
Following a complaint to Chandole police station, an FIR was filed under provisions of the The Scheduled Caste and Scheduled Tribes (Prevention of Atrocities Act), 1989, (‘SC/ST Act’) as well as charges of wrongful restraint, hurt, and criminal intimidation under the Indian Penal Code (‘IPC’). The accused, from the Reddy community, then moved to the Andhra Pradesh High Court seeking quashing of the proceedings, arguing that Anand could not legally claim the status of a Scheduled Caste under the Constitution Order, as he had converted to Christianity.
Accepting this contention, the High Court quashed the case in April 2025, holding that a person who openly professes Christianity cannot invoke protections under the SC/ST Act. It also noted inconsistencies in witness testimonies and found that the evidence did not substantiate the claim of a large-scale assault, concluding that continuing the proceedings would amount to an abuse of process.
Challenging this decision, Anand approached the Supreme Court.
What did the parties argue in the Supreme Court?
The appellant challenged the High Court’s approach to caste identity on both legal and sociological grounds. He contended that caste is determined by birth and continues to shape social realities regardless of an individual’s religious affiliation. Conversion to Christianity, therefore, does not erase the stigma, discrimination, or structural disadvantages historically attached to a Scheduled Caste identity. Denying protection under the SC/ST Act on the basis of conversion alone, thus, ignores the persistence of caste in Indian society.
Referring to a 1977 Government Order issued by Andhra Pradesh government, which extended certain benefits to Scheduled Caste converts, the appellant argued that this reflected a recognition by the State that conversion does not dissolve caste-based disadvantage, and therefore, legal protections should not be withdrawn solely on the basis of a change in religion.
The respondents, however, argued that the 1950 Order is categorical and Clause 3 notes that only those who profess Hinduism, Sikhism, or Buddhism can be recognised as members of a Scheduled Caste. The term ‘profess,’ they argued, has been consistently interpreted by courts to mean an open and public declaration of faith. On this test, the appellant’s position as a pastor left no room for ambiguity. At the relevant time, he was professing Christianity and, therefore, stood outside the constitutional definition of a Scheduled Caste.
They pointed out that neither a caste certificate nor a State Government Order could override the 1950 Order. An executive order, they added, cannot alter a Presidential Order under Article 341.
The Court noted that while Sikhism and Buddhism were later included in the 1950 Order through amendments, Christianity remains excluded, which showed that it was deliberate and binding.
What did the Court say?
At the constitutional level, the Supreme Court began by situating the issue within Articles 341 and 342 of the Constitution, which empower the President to notify Scheduled Castes and Scheduled Tribes. These provisions, the Court emphasised, are protective and designed to address historical disadvantage, but the protection is tightly governed by the Constitution Order, 1950 and its subsequent amendments.
Drawing from State of Kerala v. Chandramohanan (2004) and G.M. Arumugam v. S. Rajagopal (1975), the Court distinguished between tribe and caste as social categories. While tribal identity may survive conversion depending on continued adherence to customs and community recognition, caste, in the Court’s view, remains structurally embedded in Hindu social organisation. For Scheduled Castes, thus, the legal framework is far more rigid.
Clause 3 of the 1950 Order explicitly restricts Scheduled Caste status to persons professing Hinduism, Sikhism, or Buddhism. The Court noted that conversion to any religion not specified in the Clause would result in immediate and complete loss of Scheduled Caste status from the moment of conversion regardless of birth. The Court interpreted the word ‘profess,’ through Punjabrao v. D.P. Meshram (1964), to say that is not a matter of private belief but of public declaration and practice.
For over a decade, Anand had been functioning as a Christian pastor, conducting prayer meetings and occupying a position of religious leadership. This, the Court held, constituted a clear and public profession of Christianity.
The Court noted that while Sikhism and Buddhism were later included in the 1950 Order through amendments, Christianity remains excluded, which showed that it was deliberate and binding. Neither administrative action, such as the issuance of a caste certificate, nor state government orders extending limited concessions can override this constitutional framework. The 1977 Andhra Pradesh government order which stated that mere change of religion shall not operate as a bar to Scheduled Caste persons from securing the benefits to which they were otherwise entitled prior to conversion, was dismissed since it distinguishes between non-statutory concessions (like economic support schemes sanctioned by Andhra Pradesh Scheduled Castes Cooperative Finance Corporation) and statutory concessions like reservations or protections under the SC/ST Act.
According to the Court, the loss of SC status upon conversion to another religion outside the fold is not partial or conditional but would extend to all statutory protections, including those under the SC/ST Act. The Court rejected the possibility of holding dual identities, stating that one cannot simultaneously profess Christianity and claim Scheduled Caste status. Any claim of reconversion, it added, must meet a high evidentiary threshold, including proof of acceptance by the original caste community.
On the criminal proceedings, the Court noted that since the appellant is held not to be a Scheduled Caste member at the time of the alleged incidents, the foundational requirement for invoking the SC/ST Act collapsed. The charges under the special statute, therefore, could not stand.
On the remaining charges under IPC, the Court referred to State of Haryana v. Bhajan Lal (1990), which had laid down the circumstances under which courts may quash criminal proceedings. It found that the evidence was thin and inconsistent and the allegations, even if taken at face value, did not disclose the commission of offences under Sections 341, 323, or 506.
The judgment ultimately affirmed the High Court’s decision in its entirety.
What does this mean?
India has some 27 million Christians and at least 74 percent belong to disadvantaged social groups, including 57 percent either Scheduled Castes (SC) or Scheduled Tribes (ST). Many argue that conversion had not freed them from social and economic marginalisation. Much like the appellant in this case, who was allegedly subjected to caste-based abuse yet denied protection under the law, many converts will find themselves recognised as Dalits in the moment of humiliation, but not in the eyes of the Constitution when it comes to protection.
This ruling effectively has created a distinction within the constitutional framework where while the law acknowledges caste-based oppression and provides remedies for it, it also ties this recognition to religious identity.
The debate over the relationship between caste and religion in India’s reservation framework has evolved over decades, shaped by constitutional design, sociological findings, and continuing legal challenges.
In 1955, the Kaka Kalelkar Commission had observed that caste hierarchies and untouchability had deeply permeated even Christian and Muslim communities and in 1980, the Mandal Commission had similarly noted that caste-based inequalities persisted across religions.
In Soosai v. Union of India (1985), the Supreme Court had acknowledged that resolving the question of extending Scheduled Caste status to converts would require detailed evidence. However, the Court stopped short of granting relief, leaving the constitutional position intact.
In 2007, the Ranganath Mishra Commission made a decisive recommendation: Scheduled Caste status should be made religion-neutral, and Clause 3 should be deleted altogether.
Despite these developments, successive governments have not implemented these recommendations. In 2022, the Union government constituted a Commission of Inquiry under former Chief Justice K.G. Balakrishnan to examine whether Scheduled Caste status should be extended to Dalit converts. The Commission has yet to submit its report and has been granted multiple extensions, with the latest deadline set for April 10, 2026.