Chinthada Anand v. State of Andhra Pradesh & Ors.

 Conversion to Christianity extinguishes Scheduled Caste status for purposes of SC/ST Act, barring invocation of its protections.

Background

Legally relevant facts
The appellant, originally from the Madiga (SC) community, alleged caste-based assault and intimidation and filed FIR under ss. 3(1)(r), 3(1)(s), 3(2)(va) SC/ST Act and ss. 341, 323, 506 r/w s. 34 IPC. The High Court quashed proceedings under s. 482 CrPC, holding that the appellant, being a practising Christian Pastor, could not claim SC status.

Issues Framed

  1. Whether a person who has converted to Christianity can claim protection under the SC/ST Act.
  2. Whether the High Court rightly quashed proceedings under s. 482 CrPC for offences under IPC and the SC/ST Act.

Court’s Reasoning

Issue 1: Eligibility for SC/ST Act Protection

(i) Legal Rule/Test

  • Under Clause 3, Constitution (Scheduled Castes) Order, 1950, no person professing a religion other than Hindu, Sikh, or Buddhist is deemed SC.
  • “Profess” = open declaration/practice of religion.

(ii) Precedents Relied Upon

  • C.M. Arumugam v. S. Rajagopal (1976)
  • Guntur Medical College v. Y. Mohan Rao (1976)
  • M. Chandra v. M. Thangamuthu (2010)
  • C. Selvarani v. District Collector (2024)

(iii) Application
The Court held that the appellant, being a Pastor for over a decade, clearly professed Christianity. By operation of Clause 3, his SC status stood extinguished despite birth in a Scheduled Caste.

(iv) Counterarguments Rejected

  • State G.O. extending benefits to converts applies only to non-statutory concessions, not statutory rights like SC/ST Act protection.
  • Caste certificate cannot override constitutional mandate.

(v) Conclusion
The appellant ceased to be SC in law, and therefore could not invoke the SC/ST Act.

Issue 2: Quashing of IPC Offences

(i) Legal Rule/Test
Quashing justified where allegations do not disclose offence (State of Haryana v. Bhajan Lal,).

(ii) Application

  • Allegations lacked corroboration beyond complainant’s statement.
  • Witnesses did not support assault, restraint, or intimidation.
  • Evidence inconsistent and largely hearsay.

(iii) Conclusion
No prima facie case under ss. 341, 323, 506 IPC, hence continuation would be abuse of process.

Decision 

Appeal dismissed; High Court’s quashing of proceedings upheld.

Ratio

A person who openly professes Christianity loses Scheduled Caste status under Clause 3 of the Constitution (Scheduled Castes) Order, 1950 and cannot invoke statutory protections under the SC/ST Act; consequently, criminal proceedings based on such status are unsustainable.

Case Details

Citation: 2026 INSC 283
Decided on: 24 March 2026
Case Title: Chinthada Anand v. State of Andhra Pradesh & Ors.
Court: Supreme Court of India
Bench: Prashant Kumar Mishra, J.; Manmohan, J.


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