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SUPREME COURT OF INDIA
PRASHANT KUMAR MISHRA, MANMOHAN, JJ.
Chinthada Anand – Appellant
Versus
State of Andhra Pradesh And Others – Respondents
Criminal Appeal No. 1580 of 2026 (Arising Out of S.L.P. (Criminal) No. 9231 of 2025)
Decided On : 24-03-2026
(A) Constitution (Scheduled Castes) Order, 1950 – Clause 3 – Constitution (Scheduled Tribes) Order, 1950 – No person who professes a religion other than Hindu, Sikh or Buddhist shall be deemed to be a member of a Scheduled Caste – This bar under Clause 3 of Constitution (Scheduled Castes) Order, 1950 is categorical and absolute – Conversion to any religion not specified in Clause 3 results in immediate and complete loss of Scheduled Caste status from the moment of conversion regardless of birth – Claimant must demonstrably belong to a caste or tribe which is specifically notified and recognised under Clause 2 of Constitution (Scheduled Castes) Order, 1950 and Constitution (Scheduled Tribes) Order, 1950, and such status must be established by clear, cogent, and unimpeachable evidence – No statutory benefit, protection, reservation, or entitlement under Constitution or under any enactment of Parliament or State Legislature that is predicated upon membership of a Scheduled Caste can be claimed by or extended to any person who, by operation of Clause 3 of Constitution (Scheduled Castes) Order, 1950, is not deemed to be a member of a Scheduled Caste – This bar is absolute and admits no exception – A person cannot simultaneously profess and practise a religion other than ones specified in Clause 3 of Constitution (Scheduled Castes) Order, 1950 and claim membership of a Scheduled Caste at the same time – A person who professes and practices such religion for personal, social and spiritual purposes cannot in law, assert membership of a Scheduled Caste for the purpose of securing statutory benefits – The two positions are mutually exclusive and contrary to Constitutional scheme. (Para 55)
(B) Constitution (Scheduled Castes) Order, 1950 – Clause 3 – Constitution (Scheduled Tribes) Order, 1950 – Religious conversion – In cases where a person claims to have reconverted from a religion not specified in Clause 3 of Constitution (Scheduled Castes) Order, 1950 back to Hindu, Sikh or Buddhist religion, following three conditions must be cumulatively and conclusively established:
(i) There must be a clear proof that the person originally belonged to a caste notified under Constitution (Scheduled Castes) Order, 1950.
(ii) There must be credible and unimpeachable evidence of bona fide reconversion to original religion, accompanied by complete and unequivocal renunciation of religion to which conversion had taken place, total dissociation therefrom, and actual adoption and observance of customs, usages, practices, rituals, and religious obligations of original caste.
(iii) There must be satisfactory and credible evidence establishing acceptance and assimilation by members of original caste and concerned community – Mere self-proclamation is insufficient i.e., community must recognize and accept the person as one of their own – All the three conditions are mandatory and cumulative – Burden of proving reconversion lies entirely on claimant, to be proven through unimpeachable evidence – Failure to establish even one condition renders claim unsustainable. (Para 55)
(C) Constitution (Scheduled Tribes) Order, 1950 – Scheduled Tribe – A person can claim benefits under Constitution (Scheduled Tribes) Order, 1950 only if he/she continues to belong to that particular tribe in substance – If, due to conversion or long-term abandonment of tribal customs, his/her tribal identity is in doubt, that question becomes a factual matter to be determined at trial – Once a person belonging to a Scheduled Tribe converts to another religion, ultimately through passage of time, customs, rituals and other traits of that particular tribe may fall into eclipse – If in such circumstance, it is proved that person in question has completely renounced himself from customs, rituals and other traits of his tribe, and has assimilated into converted religion following practices and customs of that particular religion, reasonable inference can be drawn that such a person shall not be considered a part of tribe. (Paras 30 and 31)
(D) Constitution (Scheduled Castes) Order, 1950 – Clause 3 – Scheduled Caste – Clause 3 excludes any person who professes a religion different from Hindu, Sikh or Buddhist from being deemed a member of a Scheduled Caste – Term “profess” connotes to publicly declare or practice a religion – Essence of the word lies in open avowal of one’s religious beliefs in a manner discernible to public at large – It is not merely a question of personal belief or private conviction, but requires an outward manifestation of one’s faith – Christianity, by its very theological foundation, does not recognize or incorporate institution of caste. (Paras 38 and 39)
(E) Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 – Sections 3(1)(r), 3(1)(s), 3(2)(va) – Indian Penal Code, 1860 – Sections 341, 506 and 323 read with Section 34 – Criminal Procedure Code, 1973 – Section 482 – Alleged abuse by caste-based slurs and criminal intimidation – Entire criminal proceedings quashed by High Court holding that appellant cannot claim protection under SC/ST Act since he had been openly professing Christianity and working as a Pastor for about a decade – Pastor occupies a position of religious leadership within Christian faith, entrusted with responsibility of preaching gospel and conducting religious services in accordance with Christian doctrine – Appellant’s occupation and conduct over this extended period constitute an open and public declaration of his Christian faith – Had appellant continued to profess Hinduism, his status as a member of Scheduled Caste would have been beyond question – However, appellant now professes Christianity – Non-statutory concessions include economic support and similar welfare schemes which do not flow from statutory mandate – SC/ST Act is a statutory enactment of Parliament of India – Act serves as a crucial legal framework to protect rights and dignity of Scheduled Castes and Scheduled Tribes in India, ensuring stringent measures against offences of atrocities and promoting their welfare and security – Once appellant converted to Christianity, caste status, which he earlier enjoyed as a member of Madiga community, stood eclipsed in eyes of law – Mere possession of certificate will not be of any benefit to appellant – Court was right in holding that appellant has ceased to be a member of Scheduled Caste on his conversion to Christianity – Accordingly, appellant cannot be a person aggrieved under SC/ST Act – Absence of consistent ocular testimony identifying assailants or manner of occurrence, does not advance prosecution’s case – Allegations under Sections 341, 506 and 323 read with Section 34 of IPC are not borne out even if prosecution’s case is taken at its face value – Judgment of High Court upheld. (Paras 41, 42, 43, 46, 48, 55, 56, 57, 58, 61, 66 and 69)
Facts of the case:
Present Appeal arises out of impugned judgment dated 30.04.2025 passed by High Court of Andhra Pradesh at Amaravati in Criminal Petition No. 7114 of 2022 filed under Section 482 of Code of Criminal Procedure, 1973, whereby, High Court has quashed criminal proceedings against respondent registered for offences punishable under Sections 3(1)(r), 3(1)(s), 3(2)(va) of Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 and Sections 341, 506 and 323 read with Section 34 of the Indian Penal Code, 1860 on file of Special Court under SC/ST Act, Guntur District.
Findings of Court:
High Court, upon a careful and correct appreciation of the material on record, arrived at the conclusion that the allegations under Sections 341, 506 and 323 read with Section 34 of the IPC are not borne out even if the prosecution’s case is taken at its face value.
Result : Appeal dismissed.
Based on the provided legal document, here are the key points regarding the judgment in Chinthada Anand vs. State of Andhra Pradesh:
1. Loss of Scheduled Caste Status upon Conversion to Christianity * No person who professes a religion other than Hindu, Sikh, or Buddhist shall be deemed a member of a Scheduled Caste. This bar under Clause 3 of the Constitution (Scheduled Castes) Order, 1950 is categorical, absolute, and admits no exception (!) (!) (!) . * Conversion to a religion not specified in Clause 3 (such as Christianity) results in the immediate and complete loss of Scheduled Caste status from the moment of conversion, regardless of the person's birth (!) (!) (!) (!) . * The term "professes" requires an outward manifestation of faith discernible to the public, not merely private conviction. A person working as a Pastor for a decade constitutes an open declaration of Christian faith (!) (!) (!) (!) . * A person cannot simultaneously profess a religion other than Hindu, Sikh, or Buddhist and claim membership of a Scheduled Caste; these positions are mutually exclusive (!) (!) .
2. Inapplicability of State Government Orders to Statutory Benefits * State Government Orders (e.g., G.O. Ms. No. 341 dated 30.08.1977) that extend concessions to SC converts only apply to "non-statutory concessions" (like economic support schemes) and do not override the Presidential Order regarding statutory benefits (!) (!) (!) . * Statutory benefits, including protection under the SC/ST Act, reservations, and entitlements predicated on SC membership, are not available to converts to Christianity or Buddhism (!) (!) (!) (!) . * Central Government clarifications confirm that Centrally Sponsored Schemes and other statutory benefits cannot be extended to Converted Christians (!) (!) (!) (!) .
3. Quashing of Criminal Proceedings due to Lack of Jurisdiction * The Special Court under the SC/ST Act lacks jurisdiction to try a case if the victim is not a bona fide member of a Scheduled Caste or Scheduled Tribe (!) (!) . * Since the appellant ceased to be a member of the Scheduled Caste upon conversion, he cannot invoke the provisions of the SC/ST Act, and the proceedings under Sections 3(1)(r), 3(1)(s), and 3(2)(va) of the SC/ST Act were rightly quashed (!) (!) (!) (!) .
4. Insufficiency of Evidence for IPC Offences * Even if the SC/ST Act provisions were considered, the allegations under Sections 341, 506, and 323 read with Section 34 of the IPC were not borne out. * There was an absence of consistent ocular testimony identifying the assailants or the manner of occurrence; the case rested solely on the appellant's statement without independent corroboration (!) (!) (!) (!) . * Witness statements were contradictory or did not support the alleged large-scale assault or wrongful restraint (!) (!) (!) . * Continuing the proceedings would amount to an abuse of the process of the law under Section 482 of the Cr.P.C. (!) (!) .
5. Specific Postulates for Reconversion (Not Applicable Here) * If a person claims to have reconverted from a non-Hindu/Sikh/Buddhist religion back to the original religion, three cumulative conditions must be met: 1. Clear proof of original caste membership. 2. Credible evidence of bona fide reconversion and total dissociation from the new religion. 3. Satisfactory evidence of acceptance and assimilation by the original community (!) (!) (!) (!) (!) (!) . * In this case, the appellant failed to establish any reconversion or community acceptance, as he continued to function as a Pastor (!) (!) (!) .
6. Reference to Precedents * The Court relied on C.M. Arumugam vs. S Rajagopal regarding the cessation of social disabilities upon conversion (!) (!) . * The Court cited Guntur Medical College vs. Y Mohan Rao regarding the requirement to profess Hindu/Sikh religion at the material time (!) (!) . * The Court referred to K.P. Manu vs. Scrutiny Committee regarding the mandatory tests for caste certificates (proof of caste, reconversion, and community acceptance) (!) (!) . * The Court applied the principles from State of Haryana vs. Bhajan Lal regarding the quashing of criminal proceedings when allegations do not disclose an offence (!) (!) (!) .
JUDGMENT :
PRASHANT KUMAR MISHRA, J.
1) Leave granted.
2) The present Appeal arises out of the impugned judgment dated 30.04.2025 passed by the High Court of Andhra Pradesh1[‘High Court’] at Amaravati in Criminal Petition No. 7114 of 2022 filed under Section 482 of the Code of Criminal Procedure, 19732[‘Cr.PC’], whereby, the High Court has quashed the criminal proceedings against respondent nos. 2 to 7 in Spl. SC No. 36 of 2021 arising out of FIR No. 08 of 2021 registered for offences punishable under Sections 3(1)(r), 3(1)(s), 3(2)(va) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 19893[‘SC/ST Act’] and Sections 341, 506 and 323 read with Section 34 of the Indian Penal Code, 18604[‘IPC’] on the file of the Special Court under the SC/ST Act, Guntur District
FACTUAL MATRIX
3) The appellant in the present proceedings is Chinthada Anand, resident of Kothapalem Village, Pittalavanipalem Mandal, Guntur District. He claims to belong to the Madiga community, a Scheduled Caste and states that for nearly ten years prior to the incident, he had been conducting Sunday prayer meetings as a Pastor at different houses in the village, including the house of one Doma Koti Reddy.
4) According to the appellant, in December 2020, he began receiving abusive and intimidating telephone calls from unknown numbers, in which he was allegedly abused by caste-based slurs and was threatened with dire consequences. These calls, according to him, were on account of his religious activities and his presence in the village as a Pastor.
5) The first incident is stated to have occurred on 03.01.2021. The appellant alleges that while he was conducting Sunday prayers at around noon at the house of Doma Koti Reddy, one of the accused called him outside, assaulted him by slapping and striking him, abused him by referring to his caste, and warned him against continuing the prayer meetings. The appellant states that he did not retaliate.
6) The second and principal incident is stated to have occurred on 24.01.2021. It is alleged that after completing Sunday prayers and while returning home, the appellant was wrongfully restrained at the entrance of the nearby hamlet by respondent nos. 2 to 7 and twenty-five others. He alleged that his mobile phone and vehicle keys were forcibly snatched, he was dragged, beaten and abused by caste name in public view, and threatened with death. It is also alleged that threats were extended to kill his family members and kidnap his children.
7) On the next day, i.e., 25.01.2021, the appellant submitted a written complaint before Chandole Police Station. On the basis of the said complaint, FIR No. 08 of 2021 came to be registered on 26.01.2021 for the offences punishable under Sections 3(1)(r), 3(1)(s), 3(2)(va) of the SC/ST Act and Sections 341, 506, 323 read with Section 34 of the IPC.
8) Investigation was undertaken by the Sub-Divisional Police Officer, Bapatla. During the course of investigation, statements of the appellant, his wife and several villagers were recorded. The appellant was medically examined and the injury sustained by him was certified to be simple in nature. The Tahsildar conducted verification regarding the caste status of the appellant and issued a certificate showing him as belonging to Hindu-Madiga community (Scheduled Caste), while the accused persons admittedly belonged to the Reddy community (OC category).
9) Upon completion of investigation, the Police filed the charge-sheet on 30.04.2021, which was taken on file as Spl. SC No. 36 of 2021 before the Special Court under the SC/ST Act for Guntur District. All the aforementioned offences were included in the charge-sheet.
10) The accused persons thereafter approached the High Court by filing a petition under Section 482 of the Cr.PC seeking quashing of the proceedings. The primary ground urged before the High Court was that the appellant had admittedly converted to Christianity and was working as a Pastor for about ten years, and therefore,
(1) Scheduled Caste – No person who professes a religion other than Hindu, Sikh or Buddhist shall be deemed to be a member of a Scheduled Caste – This bar under Clause 3 of Constitution (Scheduled Ca....
Conversion from Hinduism to Christianity disqualifies individuals from Scheduled Caste status, impacting eligibility for caste-based benefits.
Religious conversion does not permit an individual to claim caste benefits under law, and statements under Section 161 Cr.P.C. are not considered formal evidence in court.
A converted Christian cannot invoke the SC ST (Prevention of Atrocities) Act as they cease to be a member of the Scheduled Caste community upon conversion.
Conversion to Christianity results in the loss of caste status; reconversion requires proof of acceptance by the original community.
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The legal provisions for prosecution of offenders who obtained false caste certificates were upheld, and the court relied on the decision of the Hon'ble Apex Court in Jagadish Bihara's case to dismis....
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