In a significant judgment impacting the interpretation of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act), the Andhra Pradesh High Court has ruled that a person who converts to Christianity cannot invoke protections under the SC/ST Act. The Court held that caste is a concept alien to Christianity, and once a person leaves the Hindu fold by converting, they cease to be a member of a Scheduled Caste, irrespective of whether their caste certificate is formally cancelled.
Case Background: Pastor Files Complaint under SC/ST Act
The ruling came in the case titled Akkala Ram Reddy v The State of Andhra Pradesh, wherein a group of individuals were booked under the SC/ST Act and relevant sections of the Indian Penal Code (IPC) for allegedly using casteist slurs and physically assaulting a Christian pastor.
The complainant, a Dalit man who had converted to Christianity over a decade ago, claimed to have been targeted on caste grounds. He had been serving as a pastor for ten years at the time of the incident. Based on his complaint, the police filed a First Information Report (FIR) under the SC/ST Act along with IPC provisions.
The accused petitioners sought quashing of the proceedings, arguing that the SC/ST Act could not be applied against them since the complainant, having converted to Christianity, was no longer entitled to the protections available under the Act.
High Court’s Ruling: Caste Ends with Conversion
Justice Harinath N of the Andhra Pradesh High Court accepted the argument and quashed the criminal proceedings, holding that the SC/ST Act is applicable only to persons who continue to belong to Scheduled Castes or Scheduled Tribes under the constitutional framework.
“Only a person belonging to Scheduled Caste and Scheduled Tribe can invoke the provisions of SC, ST (Prevention of Atrocities) Act… The 2nd respondent had voluntarily converted to Christianity and was admittedly working as a Pastor in a Church for the last 10 years as on the date of the incident. Thus, the 2nd respondent cannot be permitted to invoke the provisions of the protective legislation.”
The Court emphasized that the very basis of the SC/ST Act is rooted in the caste-based social structure of Hinduism. Once a person renounces Hinduism and adopts Christianity, the traditional socio-religious barriers and disabilities that define caste cease to apply to them.
Caste Certificate Not Enough for Protection
Importantly, the Court addressed the issue of the complainant still holding a Scheduled Caste certificate. It clarified that formal cancellation of the certificate is not determinative:
“Mere non-cancellation of the caste certificate by the authority to a person who has converted into Christianity cannot instill the protection granted under the Protective Legislation.”
The Court held that the act of conversion itself is sufficient to disqualify a person from claiming Scheduled Caste status. Therefore, a Dalit who converts to Christianity ceases to be a beneficiary under the protective provisions of the SC/ST Act from the day of conversion.
False Complaint, No Case under IPC Either
Apart from dismissing the applicability of the SC/ST Act, the High Court also examined the IPC charges against the accused and found them to be unsubstantial. It concluded that the complaint appeared to be false and that no purpose would be served by subjecting the petitioners to trial.
“This Court is of the considered view that a false complaint is filed and no purpose would be served if the petitioners are relegated to the trial Court and to undergo the rigmarole of trial.”
Accordingly, the Court quashed the criminal proceedings in their entirety.
Legal Representation
- Petitioners were represented by Advocate JV Phaniduth.
- Complainant was represented by Advocate Satheesh Kumar Eerla.
- State was represented by the Public Prosecutor.
Legal and Constitutional Implications
This ruling revives a long-standing debate on the eligibility of Dalit converts to Christianity or Islam to claim benefits and protections extended to Scheduled Castes under Indian law.
The Presidential Order of 1950
The Constitution (Scheduled Castes) Order, 1950—issued under Article 341—limits Scheduled Caste status to persons who profess Hindu, Sikh, or Buddhist religions. Christianity and Islam are excluded on the ground that they do not recognize the caste system.
Despite numerous legal challenges and debates, this Order remains in effect, and courts have consistently upheld the exclusion. The Andhra Pradesh High Court’s ruling is in line with earlier judgments by the Supreme Court and High Courts that have recognized the constitutional bar on extending SC benefits to Dalit converts outside Hinduism, Buddhism, or Sikhism.
Protection from Atrocities vs. Reservation Benefits
While the present case concerns criminal prosecution under the SC/ST Act, similar principles apply in contexts of reservations in education and employment. Courts have routinely held that SC status—and therefore SC-specific benefits—are not available to Dalits who convert to Christianity or Islam unless reconversion takes place or a specific constitutional amendment expands the definition.
Criticism and Concerns
Critics argue that while conversion may alter a person’s religious identity, it does not automatically erase centuries of social discrimination rooted in caste. Dalit Christians, for instance, may still face exclusion and violence rooted in their caste origin, especially in rural India. Denying them legal protection under the SC/ST Act, they argue, ignores the ground realities of caste-based oppression that persists beyond religion.
Social justice activists have long demanded that the 1950 Presidential Order be amended to include Dalit Christians and Muslims. Several commissions, including the Justice Ranganath Misra Commission, have recommended such an inclusion. However, legislative action remains pending.
Conclusion
The Andhra Pradesh High Court’s judgment in Akkala Ram Reddy v The State of Andhra Pradesh reaffirms the constitutional position that Scheduled Caste status—and consequently, protection under the SC/ST Act—is unavailable to Dalits who convert to Christianity. By holding that caste is alien to Christianity and that mere possession of a caste certificate does not confer SC status post-conversion, the Court has added to the growing judicial consensus on this issue.
While the decision brings legal clarity, it also reignites the broader debate on whether caste-based discrimination transcends religious boundaries—and whether the law should evolve to recognize and protect Dalit converts facing similar forms of social exclusion.
