“Conversion, Caste, and Constitutional Silence: A Critical Reading of Chinthada Ananda”

When Right Depend Upon Religion:

Beaten, abused by caste name, and threatened in public—yet denied protection of the law. Why? Because of religion.

The recent Supreme Court (“SC”) judgement in the case of Chinthada Ananda v State of Andhra Pradesh (“Chinthada case”) has raised serious social, legal and constitutional questions where the Hon’ble “SC” held that a person originally belonging to the Scheduled caste upon “professing” any religion other than Hinduism, Sikhism, and Buddhism cannot claim the SC/ST benefits granted under any statutes including the protection under Scheduled Caste and Schedule Tribe (Prevention of Atrocities) Act 1989 (“SC/ST ACT”). This blog undertakes a critical analysis of a recent Supreme Court judgment addressing this contentious issue of Scheduled Caste status upon conversion to Christianity. The paper begins by outlining the brief facts of the case, competing arguments advanced by both parties, and the reasoning adopted by the Court, which emphasized the interpretation of the term “profess” and held that an open declaration and practice of Christianity disentitles a person from claiming Scheduled Caste status under the constitutional framework. Further the author critically highlights the socio-legal implications of the ruling upon marginalized communities in contemporary Indian society.

Background of the case

The present Appeal arises out of the impugned judgment dated 30.04.2025 passed by the High Court of Andhra Pradesh whereby, the High Court has quashed the criminal proceedings against respondent nos. 2 to 7 registered for offences punishable under Sections 3(1)(r), 3(1)(s), 3(2)(va) of the SC/ST and Sections 341, 506 and 323 read with Section 34 of the Indian Penal Code, 1860.

Factual Matrix of the Case

1. The appellant in the present proceedings is Chinthada Anand, resident of Kothapalem Village, 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.
2. 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.
3. The first incident has occurred on 03.01.2021. The appellant alleges that while he was conducting Sunday prayers 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.
4. The second incident 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.
5. On the next day, the appellant submitted a written complaint before Chandole Police Station, investigations conducted, charge sheet was filed before Special Court under the SC/ST Act for Guntur District All the aforementioned offences were included in the charge-sheet.
6. The accused persons then approached the High Court under Section 482 of the CrPC seeking quashing of the proceedings. The primary ground urged before the High Court was that the appellant had converted to Christianity hence in view of the Constitution (Scheduled Castes) Order, 1950, they could not legally claim the status of a Scheduled Caste so as to invoke the provisions of the SC/ST Act. Vide impugned judgment dated 30.04.2025, the High Court had quashed the entire criminal proceedings holding inter alia that the appellant Could not claim protection under the SC/ST Act since he has converted to Christianity.
7. Aggrieved, the appellant has preferred the present Appeal challenging the quashing of proceedings before the Hon’ble SC.

Issues Before the Court.

1. Whether a person who converts to Christianity can continue to claim Scheduled Caste status?
2. Whether such a person can invoke protection under the SC/ST (Prevention of Atrocities) Act?
3. Whether conversion affects constitutional benefits granted to Scheduled Castes?

Arguments of the Appellant

Learned counsel for the appellant submitted that the High Court wrongly quashed the criminal proceedings despite there being a prima facie case of physical assault, caste-based abuse and criminal intimidation. It was contended that the appellant was subjected to public humiliation by referring to his caste name, thereby attracting the provisions of the SC/ST Act . The counsel further argued that the High Court gravely erred in holding that conversion to Christianity disentitles the appellant from invoking statutory protection, emphasizing that caste is a matter of birth and not of faith, and that social disabilities attached to caste continue irrespective of religious conversion. To bolster the submission counsel relied upon G.O. Ms. No. 341 dated 30.08.1977 to assert that mere change of religion does not bar Scheduled Caste persons from availing benefits available prior to conversion.

Arguments of Respondent

Per contra, learned senior counsel for respondent supported the impugned judgment and submitted that the High Court has rightly exercised its jurisdiction under Section 482 of the CrPC to quash the proceedings, as the very foundation for invoking the provisions of the SC/ST Act was absent. Counsel further submitted that appellant is a pastor (A leader in Christians who preaches and spread the gospels) for more than a decade showing professes and practices Christianity. In such situation, he cannot claim the protection of the SC/ST Act, which is applicable only to persons who are members of the Scheduled Castes or Scheduled Tribes within the ambit of clauses (24) and (25) of Article 366 read with Articles 341 and 342 of the Constitution of India, 1950.

Counsel pointed out that Clause 3 of the Constitution (Scheduled Castes) Order, 1950 (“SC Order”) unequivocally provides that no person who professes a religion different from Hinduism, Sikhism or Buddhism shall be deemed to be a member of a Scheduled Caste. It was further argued that the expression “professes” has consistently been interpreted by this Court to mean open declaration for practice of a religion, and that the relevant test is the material time when the benefit is claimed.

Clause 3 of the SC Order is produced hereunder:

[3.] Notwithstanding anything contained in paragraph 2, no person who professes a religion different from the Hindu, the Sikh or the Buddhist religion shall be deemed to be a member of a Scheduled Caste.

Counsel further contends that the mere production of caste certificate by the appellant is of no assistance as it has been issued by the state government and therefore it cannot override the “SC Order” 1950 which has been issued by the President in view of the exercise of powers conferred under clause (1) of Article 341 of the Constitution.

Court’s Ruling.

Before examining the legality of the HC order, SC first examined the meaning of word “Scheduled Case”. The initial question which is required to be posed is what is a ‘caste’?

In C.M. Arumugam vs. S Rajagopal,1975 a three-Judge Bench of this Court had the opportunity to discuss on the question: The relevant para is produced here:

When we speak of a caste, we do not mean to refer in this context to the four primary castes, but to the multiplicity of castes and sub-castes which disfigure the Indian social scene. “A caste”, as pointed out by the High Court of Madras in Coopoosami Chetty v. Duraisami Chetty “is a voluntary association of persons for certain purposes”. It is a well-defined yet fluctuating group of persons governed by their own rules and regulations for certain internal

purposes.

Sir H. Risley has shown in his book on People of India how castes are formed based not only on community of religion, but also on community of functions. It is also pointed out by Sankaran Nair, J. in Muthusami v. Masilamani:

“A change in the occupation sometimes creates a new caste. A common occupation sometimes combines members of different castes into a distinct body which becomes a new caste. Migration to another place makes sometimes a new caste.”

Court observed that only those caste would be regarded as scheduled caste which have been listed under “SC Order” 1950 and fulfils criterion given under the Order. Court quoted that only those person can acquire the benefit of Scheduled Caste who profess and practice any religion given under clause 3 of “SC Order” i.e. Hinduism (originally there in Order), Sikhism (added in 1956) and Buddhism (added in 1990). Court relied upon Punjabrao vs. D.P. Meshram 1964 where the meaning of phrase “professes” defined as “to enter publicly into a religions state” and that for this purpose a mere declaration by a person that he has ceased to belong to a particular religion and embraced another religion would not be sufficient.

Court held that it is an unequivocal established fact that appellant professes Christianity and viewing through the lens of Punjabrao (supra), the appellant undoubtedly professes Christianity within the meaning of Clause 3 of the Constitution (Scheduled Caste) Order, 1950). Therefore, the statutory benefits of SC/ST Act cannot be extended to the appellant. Court reiterated, had the appellant continued to profess Hinduism, his status as a member of the Scheduled Caste would have been beyond question but not now.

Court also observed that as per G.O. of Andhra Pradesh government, only non-statutory benefits can be conferred on person who has converted to religion other than Hinduism, Sikhism and Buddhism such like benefits under economic support schemes sanctioned by Andhra Pradesh Scheduled Castes Cooperative Finance Corporation and no statutory benefit including protection under SC/ST Act cannot be conferred.

PROOF OF RECONVERSION

The court in the instant case held that where a person claims to have reconverted from a religion not specified in Clause 3 of the Constitution “SC” Order, 1950 back to Hindu, Sikh or Buddhist religion, the following three conditions must be cumulatively established to get the benefit of reconversion:

1. There must be a clear proof that the person originally belonged to a caste notified under the Constitution said Order of 1950.
2. There must be credible and unimpeachable evidence of bona fide reconversion to the original religion, accompanied by complete and unequivocal renunciation of the religion to which conversion had taken place.
3. There must be satisfactory and credible evidence establishing acceptance and assimilation by the members of the original caste and the concerned community. Mere self-proclamation is insufficient i.e., the community must recognize and accept the person as one of their own.

All the above three conditions are mandatory and must be cumulatively established. The burden of proving reconversion lies exclusive on person claiming to get benefit entirely on the claimant, to be proven through unimpeachable evidence. Failure to establish any of condition would make claims untenable.

Implications of Court’s Ruling:

Strength of the Judgement

The judgement delivered by the Supreme Court in legal terms aims to deliver the benefits and protection only to the Original member of the SC/ST community. It would ensure that no one should misuse the provision of SC/ST Act after conversion to any other religion which does not recognize caste distinction like Islam or Christianity. Further, the language of the Article 341 has been strictly interpreted to include those caste within SC/ST community which have been recognized by the Presidential Order. Overall, to curb the menace of fake cases and to prevent the abuse of process of law, the said judgement has been delivered along with to ensure that only actual SC/ST community could reap the benefit of statutory laws.

Limitations of the Judgement

The judgement was delivered when a Christian Pastor approached the court to demand protection under SC/ST Act 1989 as he belonged to the SC community ten years ago before being a Christian for at least 10 years. The Apex Court dismissed the plea upon relying on clause 3 of Constitution “SC Order” 1950 which states that only person belonging to Hinduism, Sikhism, Buddhism can reap the benefit of he said Act and not anyone else. The judgement has ignored the real welfare-approach for SC/ST people who have chosen any other religion other than mentioned in clause 3.

It has significant limitations.

1. Erosion of Caste Based Identification- The judgment proceeds on the categorical premise that “conversion to any religion not specified in Clause 3 results in immediate and complete loss of Scheduled Caste status regardless of birth.” The reasoning has arbitrarily ignored the social realities of India’s caste system. In theory, one may say that caste is no longer grounded on birth, but in reality, this cannot be ignored, because in India people still form perceptions and believe that the caste of a person remains the same into which he or she is born. Thus, the Hon’ble Court has overlooked the practical implications of the judgment by stating that upon conversion a person’s caste is extinguished. If this reasoning continues to remain in force, thousands of people who have now converted to religions like Christianity but originally hail from SC or ST communities would not get justice and would be subjected to brutal mental torture, inhumane abusive language, and caste based slurs, as there is a strong possibility that people from their original community may criticize and target them very harshly.
2. Violation of Religious Autonomy- If a person belonging to a Scheduled Caste or Scheduled Tribe becomes influenced by the tenets, principles, and spiritual teachings of another religion not mentioned under Clause 3 of the Constitution SC Order, and embraces that religion in exercise of the fundamental right guaranteed under Article 25 of the Constitution, and thereafter is subjected to caste-based abuse and threats of dire consequences, can it ever be justified to ignore such injustice? Would denying such a person legal protection and redress merely on the ground of religious conversion not amount to a failure of justice itself? This is what the court has applied in present case by directly rejecting the concerns of the appellant.
3. Religion-Sole Ground to Deliver Justice- As per the “SC Order” 1950, court tends to reject the pleas of persons who originally hailed from these very caste mentioned in the order. This is very subjective and arbitrary classification of the Scheduled Caste people who originally hailed from it but now converted to other religion than mentioned under the Order. Court is of the view that only because a person does not belong to the mentioned religion his atrocities cannot be addressed. This is irony to what has been mentioned under Article15 of the Constitution that no one person shall be discriminated on the grounds of religion, race, caste etc.
4. Creating Practical Hurdles and Evidentiary Burden: This Court, in instant case introduces stringent conditions for reconversion, requiring “clear proof,” “credible and unimpeachable evidence,” and “acceptance by the community,” all of which are “mandatory and cumulative”. This imposes an onerous on individuals seeking to reclaim Scheduled Caste status. Reliance on K.P. Manu v. Scrutiny Committee further reinforces this rigid standard. In practice, such requirements create significant hurdles for example community may refuse to accept the person again as a member due to personal enmity or otherwise consequently, impacting the vulnerable and making them from vulnerable to more vulnerable and marginalized legging in getting justice thereby frustrating the very object of the SC/ST Act, which is to provide “stringent measures against offences of atrocities”

Conclusion

The case Chinthada Ananada v. State of Andhra Pradesh marks a turning point in India’s justice delivery system. It places the “converts SC/ST” on different footing than those who have not converted to any religion like Christianity or Islam. Though it aims to ensure that only real SC/ST people get the benefit of the statutory enactments but at the same time it overlooks the real and practical negative implications of the judgement for those who after conversion face atrocities on account of that conversion. The Hence the judgement make unreasonable classification between the members of the same community without rational nexus between the classification and objects sought to be achieved narrowing down the interpretation of SC/ST provisions and violating the right to equality, right against discrimination, and right to profess the religion of one’s own by making subject to various limitations thereby making the constitutional guarantees as mere fleeting promises and paper hopes.

Case Details:

Full name of the case- Chinthada Ananda v State of Andhra Pradesh

Citation- Criminal Appeal No. 1580 Of 2026

Bench: J. Prashant Kumar Mishra, J. Manmohan.

Layba Rana is a B.A. LL.B. (Hons.) student at the Faculty of Law, Jamia Millia Islamia, and serves as Co-Founder and Newsletter Head at FairLex, with interests in constitutional, criminal, and intellectual property law.

Arsha Rana is a second-year B.A. LL.B. student at the Faculty of Law, Jamia Millia Islamia, serving as Co-Founder and Content Head at FairLex, with interests in constitutional law, criminal law, and contemporary socio-legal issues.