It is definitely most significant to pay our utmost unremitting attention especially those who themselves convert to other religion that in a major development directly affecting those who convert, we see that none other than the Supreme Court itself in a most learned, laudable, landmark, logical and latest judgment titled Chinthada Anand vs State of Andhra Pradesh and others in Criminal Appeal No. 1580 of 2026 (Arising out of S.L.P. (Criminal) No. 9231/2025) and cited in Neutral Citation No.: 2026 INSC 283 that was pronounced on 24 March 2026 minced absolutely just no words to hold explicitly that religious conversion results in “immediate and complete loss” of Scheduled Caste status from the moment it occurs, regardless of birth. By extension, all statutory benefits terminate automatically and upheld the Andhra Pradesh High Court’s view. To put it differently, the Apex Court has made it indubitably clear that no benefit of caste identity available to a person after religious conversion. In hindsight, it may be recalled that a Bench of the Andhra Pradesh High Court in Akkala Rami Reddy v State of Andhra Pradesh quashed the FIR that had been lodged under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 and provisions of the Indian Penal Code, 1860. The High Court held that the caste system was alien to Christianity and the IPC allegations lacked corroboration.
To recap briefly, we see that Chinthada Anand was born into the Madiga community which is a Scheduled Caste community in Andhra Pradesh. He converted to Christianity and spent over a decade conducting Sunday prayer meetings as a pastor and his role as treasurer of the local Pastors Fellowship constituted an unequivocal profession of Christianity as held by the Apex Court Bench. In January 2021, he alleged that members of a locally dominant community assaulted him, abused him by his caste identity and threatened to kill him and his family.
It merits noting that the Apex Court Bench then ruled that Christianity does not “by its very theological foundation” recognize caste. It relied on the New Testament Galatians 3:28: “There is neither Jew nor Gentile, neither slave nor free, nor is there male and female, for you are all one in Christ Jesus.” The top court reasoned that “the social and economic disabilities arising because of Hindu religion cease” once a person converts from Hinduism to Christianity as per the Constitution Bench decision in Principal, Guntur Medical College v Y Mohan Rao (1976) and the three-judge Bench in CM Arumugam v S Rajagopal (1975). It must also be borne in mind that the Apex Court in C. Selvarani (November 2024), Hon’ble Mr Justice Pankaj Mithal and Hon’ble Mr Justice R Mahadevan held clearly that claiming Scheduled Caste status after conversion amounted to “fraud on the Constitution”.
At the very outset, this robust, remarkable, rational and recent judgment authored by Hon’ble Mr Justice Prashant Kumar Mishra for a Bench of Apex Court comprising of himself and Hon’ble Mr Justice Manmohan sets the ball in motion by first and foremost putting forth in para 2 that, “The present Appeal arises out of the impugned judgment dated 30.04.2025 passed by the High Court of Andhra Pradesh (‘High Court’) at Amaravati in Criminal Petition No. 7114 of 2022 filed under Section 482 of the Code of Criminal Procedure, 19732, 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, 1989 (‘SC/ST Act’) and Sections 341, 506 and 323 read with Section 34 of the Indian Penal Code, 1860 (‘IPC’).”
To put things in perspective, the Bench then envisages in para 3 that, “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.”
As it turned out, the Bench then enunciates in para 4 that, “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.”
To recapitulate, the Bench recalls in para 5 that, “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.”
Further, the Bench discloses in para 6 that, “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.”
Going ahead, the Bench then also reveals in para 7 that, “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.”
Delving deeper, the Bench then lays bare in para 8 that, “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).”
Furthermore, the Bench observes in para 9 that, “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.”
Be it noted, the Bench notes in para 11 that, “Vide impugned judgment dated 30.04.2025, the High Court had quashed the entire criminal proceedings in Spl. SC No. 36 of 2021 qua respondent nos. 2 to 7, holding inter alia that the appellant cannot claim protection under the SC/ST Act since he had been openly professing Christianity and working as a Pastor for about a decade. The High Court was of the view that caste system is not recognised in Christianity and that a person who has converted and continues to actively work as a Pastor and profess Christianity, cannot, in law, claim protection under the SC/ST Act.”
While continuing in the same vein, the Bench points out in para 12 that, “Further, the High Court noted that the statements of witnesses did not consistently support the appellant’s version of a large group assault, and only a limited corroboration was available for the alleged restraint and attack, the medical evidence showed only a simple injury sustained by the appellant. On an overall assessment, the High Court held that continuation of the criminal proceedings against respondent nos. 2 to 7 would amount to an abuse of the process of law.”
As a corollary, the Bench then holds in para 13 that, “Aggrieved, the appellant has preferred the present Appeal challenging the quashing of proceedings against respondent Nos. 2 to 7 in Spl. SC No. 36 of 2021 arising out of FIR No. 08 of 2021.”
Most significantly, the Bench encapsulates in para 56 what constitutes the cornerstone of this notable judgment postulating precisely that, “Reverting to the facts of the present case, it is not in dispute that the appellant was originally born into the Madiga community of Scheduled Caste. It is equally undisputed that he subsequently embraced Christianity. The submission advanced on behalf of the appellant that he continues to retain his Scheduled Caste status by birth notwithstanding such conversion cannot be accepted. When the postulates enunciated hereinabove are applied to the facts at hand, it becomes manifest that for a person to be recognised as a member of a Scheduled Caste, he must be professing the Hindu religion or such other religions as are expressly recognised under the Constitution (Scheduled Castes) Order, 1950. 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.”
Equally significant is that the Bench propounds in para 57 holding that, “In the present case, it is not the case of the appellant that at any stage, he had reconverted from Christianity to his original religion or has been accepted back into the fold of the Madiga community. On the contrary, the evidence on record unmistakably establishes that the appellant continues to profess Christianity and has been functioning as a Pastor for more than a decade, conducting regular Sunday prayer meetings in different houses of the village. It is also an admitted position that at the time of the alleged incident, the appellant was conducting prayer meeting as a Pastor at the house of one Doma Koti Reddy. These concurrent facts leave no room for doubt that the appellant continues to remain a Christian on the date of the occurrence.”
It is worth noting that the Bench notes in para 58 that, “As far as the contention of the learned counsel for the appellant placing reliance on the caste certificate is concerned, we are of the view that mere possession of the certificate will not be of any benefit to the appellant. The said caste certificate is mandatorily required to be in consonance with the Constitution (Scheduled Castes) Order, 1950. In this regard, we place reliance on the decision of this Court in K.P. Manu vs. Scrutiny Committee for Verification of Community Certificate in C.A. No. 7065 of 2008 pronounced on 26 February 2015, wherein a Division Bench had laid out three mandatory tests to be established by a person who claims to be a beneficiary of a caste certificate:
“38. In our considered opinion, three things that need to be established by a person who claims to be a beneficiary of the caste certificate are : (i) there must be absolutely clear-cut proof that he belongs to the caste that has been recognised by the Constitution (Scheduled Castes) Order, 1950; (ii) there has been reconversion to the original religion to which the parents and earlier generations had belonged; and (iii) there has to be evidence establishing the acceptance by the community. Each aspect according to us is very significant, and if one is not substantiated, the recognition would not be possible.” (emphasis supplied).”
Resultantly, the Bench directs and holds in para 59 that, “From the above, it is clear that 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. In the present case, we 13 (2015) 4 SCC 1 have no hesitation in holding that the appellant, having ceased to be a member of the Madiga community upon his conversion to Christianity and having failed to establish any subsequent reconversion, does not satisfy the mandatory Constitutional requirement for claiming the status of Scheduled Caste.”
Most forthrightly, the Bench propounds in para 60 holding that, “At the very outset, it must be unequivocally stated that the offences registered under the SC/ST Act against respondent nos. 2 to 7 at the instance of the appellant cannot be sustained. Having already held that the appellant ceased to be a member of the Scheduled Caste community upon his conversion to Christianity, he cannot subsequently invoke the provisions of the SC/ST Act. The said statute is a special legislation enacted with the avowed object of preventing atrocities against the members of the Scheduled Castes and Scheduled Tribes and once the foundational requirement of caste status stands extinguished, the statutory protection thereunder is no longer available.”
Most rationally, the Bench then directs and holds in para 61 that, “Therefore, we are of the view that the High Court was right in holding that the appellant has ceased to be a member of the Scheduled Caste on his conversion to Christianity. Accordingly, the appellant cannot be a person aggrieved under the SC/ST Act.”
While citing the relevant case laws, the Bench points out in para 68 that, “In Bhajan Lal (supra) and recently in Neeharika Infrastructure Private Limited vs. State of Maharashtra (2021) 19 SCC 401 (Para 33), this Court has clearly held that 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.”
It would be instructive to note that the Bench then hastens to add in para 69 noting that, “We are of the view that the 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.”
Finally and from the aforesaid analysis, the Bench then deems it fit to direct and hold in para 70 that, “In view of the above analysis, we find no substance in the Appeal which fails and is hereby dismissed.”
In a nutshell, what can be reasonably drawn from this notable judgment is that no benefit is available to a person after religious conversion to some other religion as we see here in this leading case also. So it is definitely in the best interest of the person who quickly converts to other religion of Islam or Christianity from Hindu religion to think hundred times before conversion because ultimately it is they themselves who convert who will suffer most because of their conversion and will lose the iron clad protection that is available to them while they were Hindus. Most recently, the Apex Court Bench on July 15, 2026 while dismissing the review petition of this very notable case held most explicitly stating that, “As per Office Report dated 26.5.2026, the Review Petition is defective. It further states that despite the defects being notified, the petitioner has not cured the defects. In the interest of justice, the defects raised by the Registry are waived. Application seeking oral hearing of the Review Petition is rejected. We have gone through the Review Petition and perused the judgment dated 24.03.2026 which has been sought to be reviewed. There is no error apparent on the record. The Review Petition is, accordingly, dismissed.”
