Supreme Court Clarifies SC Status After Conversion: Insights from Chinthada Anand Vs State of Andhra Pradesh and Others

1. Background of the Dispute

The Supreme Court in Chinthada Anand Vs State of Andhra Pradesh and Others examined a crucial issue: whether a person born into a Scheduled Caste, who has converted to Christianity and is openly practising that faith, can still claim Scheduled Caste status and seek protection under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (“SC/ST Act”).

The appellant, Chinthada Anand, was originally from the Madiga community, a Scheduled Caste listed in the Constitution (Scheduled Castes) Order, 1950 for Andhra Pradesh. He was residing in Kothapalem Village, Pittalavanipalem Mandal, Guntur District. For about a decade before the incident, he had been working as a Pastor and conducting Sunday Christian prayer meetings at various houses in the village, including the residence of one Doma Koti Reddy.

1.1 Alleged Incidents and FIR

According to the assessee (complainant):

  • In December 2020, he began receiving abusive phone calls from unidentified persons, allegedly containing caste-based insults and threats linked to his religious activity in the village.
  • First incident – 03.01.2021:
    • While leading Sunday prayers at the house of Doma Koti Reddy around noon, one accused allegedly called him outside, assaulted him (slaps and blows), hurled caste abuse, and warned him against continuing the prayer meetings.
    • The assessee states that he did not retaliate.
  • Second incident – 24.01.2021:
    • After finishing Sunday prayers and on his way home, he was allegedly stopped near a hamlet entrance by respondent nos. 2 to 7 and around twenty-five others.
    • His mobile phone and vehicle keys were allegedly snatched, he was dragged and beaten in public view, abused by caste name, and threatened with death.
    • Further threats were allegedly issued to kill his family and kidnap his children.

On 25.01.2021, the assessee filed a written complaint at Chandole Police Station. Based on this complaint, FIR No. 08 of 2021 was registered on 26.01.2021 under:

  • Sections 3(1)(r), 3(1)(s), 3(2)(va) of the SC/ST Act, 1989; and
  • Sections 341, 506, 323 read with Section 34 of the Indian Penal Code, 1860.

Investigation was conducted by the Sub-Divisional Police Officer, Bapatla. The assessee, his wife, and several villagers were examined. The medical report found a simple injury. The Tahsildar issued a caste certificate recording the assessee as belonging to the Hindu-Madiga Scheduled Caste, while the accused were from the Reddy (OC) community.

After completion of investigation, a charge-sheet dated 30.04.2021 was filed and numbered as Spl. SC No. 36 of 2021 before the Special Court under the SC/ST Act, Guntur District.

1.2 High Court’s Intervention under Section 482 CrPC

The accused (respondent nos. 2 to 7) approached the High Court of Andhra Pradesh by filing Criminal Petition No. 7114 of 2022 under Section 482 of the Code of Criminal Procedure, 1973.

Their core contention was:

  • The assessee had converted to Christianity and had been functioning openly as a Pastor for around ten years.
  • In view of Clause 3 of the Constitution (Scheduled Castes) Order, 1950, a person who professes a religion other than Hinduism, Sikhism or Buddhism cannot legally be treated as a Scheduled Caste.
  • Hence, the foundational requirement of the SC/ST Act (that the victim must legally be an SC/ST) was missing.

By judgment dated 30.04.2025, the High Court:

  • Quashed the proceedings in Spl. SC No. 36 of 2021 as against respondent nos. 2 to 7;
  • Held that the assessee, being a practising Christian Pastor, was outside the definition of Scheduled Caste under the Presidential Order;
  • Observed that caste structure is not recognised under Christianity; and
  • Found the factual support for a large-scale group assault to be weak, noting only simple injuries and partial corroboration.

The assessee appealed to the Supreme Court challenging this quashing order.

2. Arguments Before the Supreme Court

2.1 Submissions from the Appellant (Assessee)

Counsel for the assessee advanced the following:

  • There was a clear prima facie case of physical assault, wrongful restraint, threats, and caste-based insults. The High Court erred in quashing proceedings at the threshold under Section 482 CrPC.
  • Caste, according to the assessee, is a matter of birth, not faith. Conversion to another religion does not erase the social stigma and discrimination associated with one’s caste origin.
  • He continues to suffer abuse and discrimination due to his birth in the Madiga community, irrespective of his current religious faith.
  • Reliance was placed on G.O. Ms. No. 341 dated 30.08.1977 issued by the Government of Andhra Pradesh, which indicated that mere conversion should not operate as a bar to Scheduled Caste persons obtaining benefits they were entitled to prior to their conversion.

2.2 Submissions from Respondents

Learned senior counsel for respondent nos. 2 to 7 supported the High Court’s order and argued: