CHINTHADA ANAND v. STATE OF ANDHRA PRADESH
Legal Consequences of Religious Conversion on Scheduled Caste Status and the Inapplicability of the SC/ST Act to Converts to Christianity.
Court: Supreme Court of India
Citation: 2026 INSC 283
Decision Date: 24-03-2026
List of Laws
The Constitution of India, 1950 (Articles 341, 342, and 366); Constitution (Scheduled Castes) Order, 1950; Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989; The Indian Penal Code, 1860 (Sections 323, 341, 506, and 34); The Code of Criminal Procedure, 1973 (Section 482)
- Facts: The appellant, Chinthada Anand, was born into the Madiga community (a Scheduled Caste) but had been practicing as a Christian Pastor for over a decade. He alleged that in January 2021, he was twice assaulted, restrained, and subjected to caste-based slurs by the respondents, who belonged to the Reddy community. Following a police investigation, a charge-sheet was filed for offences under the SC/ST Act and various sections of the Indian Penal Code. The respondents contended that the appellant, having converted to Christianity, could no longer claim Scheduled Caste status, thereby making the SC/ST Act inapplicable. They also argued that the IPC allegations were unsubstantiated by witness statements.
- Procedural Posture: The respondents moved the High Court of Andhra Pradesh under Section 482 of the Cr.PC to quash the criminal proceedings. The High Court quashed the proceedings, leading the appellant to challenge that decision before the Supreme Court of India.
- Issue: Does a person born into a Scheduled Caste continue to retain that status and the protection of the SC/ST Act after converting to Christianity? Furthermore, was the High Court justified in quashing the IPC proceedings based on lack of corroborative evidence?
- Holding: No, a person who professes a religion other than Hinduism, Sikhism, or Buddhism ceases to be a member of a Scheduled Caste as per the Constitution (Scheduled Castes) Order, 1950. Consequently, the SC/ST Act cannot be invoked. Yes, the quashing of IPC proceedings was justified as the allegations lacked a foundational basis in the evidence collected.
- Reasoning: The Court reasoned that Clause 3 of the Constitution (Scheduled Castes) Order, 1950, is categorical in excluding those who "profess" a religion different from Hinduism, Sikhism, or Buddhism from the definition of Scheduled Castes. The term "profess" implies an open declaration or practice. Since the appellant was an active Pastor, he indubitably professed Christianity, resulting in the "eclipse" of his caste status. State Government Orders providing non-statutory concessions to converts cannot override the Presidential Order regarding statutory protections. Regarding the IPC offences, the Court applied the principles of "Bhajan Lal", noting that the material collected during investigation contained significant contradictions and lacked independent corroboration, making the continuation of trial an abuse of the process of law.
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