Person Professing Christianity Cannot Claim Scheduled Caste Status To Invoke SC/ST Act: Supreme Court

"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." Supreme Court, in a significant ruling, held that a person who openly professes and practices Christianity is excluded from the ambit of Scheduled Castes and therefore cannot invoke the protections of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

A bench of Justice Prashant Kumar Mishra and Justice Manmohan observed that Clause 3 of the Constitution (Scheduled Castes) Order, 1950, is categorical in providing that no person who professes a religion different from Hinduism, Sikhism, or Buddhism shall be deemed a member of a Scheduled Caste. The Court emphasized that once the foundational requirement of the victim’s caste status is extinguished due to conversion, the statutory protections of the SC/ST Act are no longer available.

The appellant, Chinthada Anand, was born into the Madiga community, a notified Scheduled Caste, but had been serving as a Christian Pastor for over a decade. He filed an FIR alleging that he was subjected to caste-based slurs, physical assault, and criminal intimidation by members of the Reddy community during his religious activities. The High Court of Andhra Pradesh quashed the proceedings, prompting this appeal where the appellant argued that caste is a matter of birth that transcends religious faith.

The primary question before the court was whether a person who has converted to Christianity and serves as a Pastor can legally claim Scheduled Caste status to sustain a prosecution under the SC/ST Act. The court was also called upon to determine whether the High Court was justified in quashing associated offences under the IPC for lack of independent corroboration.

The Court began its analysis by interpreting the term "professes" as used in Clause 3 of the Constitution (Scheduled Castes) Order, 1950. Relying on the precedent in Punjabrao v. D.P. Meshram, the bench noted that to profess a religion implies an open declaration or public practice discernible to the public at large, rather than a mere private conviction. The bench found that the appellant’s role as a Pastor, his leadership in a religious fellowship, and his conduct of Sunday prayer meetings for ten years constituted an unequivocal public avowal of Christianity. "The word 'profess' in the Presidential Order appears to have been used in the sense of an open declaration or practice by a person... a declaration of one's belief must necessarily mean a declaration in such a way that it would be known to those whom it may interest."

The bench clarified that the Presidential Order of 1950, issued under Article 341 of the Constitution of India, restricts the deeming of Scheduled Caste status only to those professing Hinduism, Sikhism, or Buddhism. The Court rejected the argument that caste identity is an indelible mark of birth that survives conversion to Christianity, noting that Christianity does not recognize the institution of caste. The judgment highlighted that the bar under Clause 3 is absolute and admits no exception for statutory benefits or protections. "Irrespective of the appellant’s caste of origin, he cannot be deemed to be a member of a Scheduled Caste... Clause 3 of the Constitution (Scheduled Castes) Order, 1950 is categorical and unambiguous in its terms."

Regarding the appellant’s reliance on G.O. Ms. No. 341 issued by the Government of Andhra Pradesh, which purportedly extended concessions to SC converts, the Court held that such executive orders cannot override the Presidential Order. The bench observed that the state government's order specifically limited concessions to "non-statutory" benefits and explicitly excluded statutory reservations and protections under central enactments. The Court reiterated that the state has no authority to enlarge or modify the list of Scheduled Castes specified under Article 341. "The administrative action of the State in providing the caste certificate to the appellant cannot be in disharmony with the Constitution (Scheduled Castes) Order, 1950."

The Court further elaborated on the legal postulates for determining SC/ST status, noting a critical distinction between the two categories. While Scheduled Caste status is strictly linked to religion under the 1950 Order, Scheduled Tribe status under the Constitution (Scheduled Tribes) Order, 1950, does not prescribe a religion-based exclusion. For tribes, the determination turns on the subsistence of tribal attributes, customs, and community recognition regardless of conversion. However, for Scheduled Castes, the religious bar is a mandatory constitutional parameter. "Unlike the Constitution (Scheduled Castes) Order, 1950, the Constitution (Scheduled Tribes) Order, 1950 does not prescribe religion-based exclusion."

Addressing the quashing of Indian Penal Code offences including Sections 341 (wrongful restraint), 323 (voluntarily causing hurt), and 506 (criminal intimidation), the bench applied the standards set in State of Haryana v. Bhajan Lal. The Court found that the prosecution's case rested solely on the appellant’s statement without any independent corroboration from witnesses. The medical evidence showed only simple injuries, and the version of a large-group assault was not supported by the charge-sheet or the accompanying witnesses. The bench concluded that continuing the criminal proceedings would amount to an abuse of the process of law. "Where the uncontroverted allegations and the evidence collected during investigation do not disclose the commission of any offence, continuation of criminal proceedings would amount to an abuse of the process of law."

The Supreme Court dismissed the appeal and affirmed the High Court's decision to quash the criminal proceedings. The ruling reinforces the principle that statutory benefits and protections meant for Scheduled Castes cannot be claimed by individuals who have converted to and openly profess religions not specified in the 1950 Presidential Order.

Date of Decision: 24 March 2026