Christian converts lose Scheduled Caste status and cannot invoke protections under the SC/ST Act.

The Appellant, originally belonging to the Hindu-Madiga community (a Scheduled Caste), had been practicing as a Christian Pastor for approximately ten years

He alleged that in January 2021, the Respondents (belonging to the Reddy community) physically assaulted him, used caste-based slurs, and threatened his family due to his religious activities

An FIR was registered under Sections 3(1)(r), 3(1)(s), and 3(2)(va) of the SC/ST (Prevention of Atrocities) Act and Sections 341, 506, 323, and 34 of the IPC

The High Court of Andhra Pradesh quashed the proceedings, reasoning that the Appellant’s profession of Christianity disqualified him from claiming Scheduled Caste (SC) status

1. Whether a person born into a Scheduled Caste but professing Christianity can claim protection and benefits under the SC/ST (Prevention of Atrocities) Act, 1989

2. Whether the High Court was justified in quashing the criminal proceedings for offences under the IPC alongside the SC/ST Act

The Court primarily applied Article 341 of the Constitution and Clause 3 of the Constitution (Scheduled Castes) Order, 1950, which mandates that no person professing a religion other than Hindu, Sikh, or Buddhist shall be deemed a member of a Scheduled Caste

It relied on Punjabrao v. D.P. Meshram, which defined "profess" as a public declaration or outward manifestation of faith

The Court also applied the three-fold test for reconversion from K.P. Manu v. Scrutiny Committee, requiring proof of origin, bona fide reconversion, and community acceptance

For quashing of IPC offences, it applied the principles from State of Haryana v. Bhajan Lal, which allow quashing where allegations, even if accepted, do not prima facie constitute an offence

The Court determined that the Appellant, by serving as a Pastor and conducting Sunday prayers for a decade, publicly "professed" Christianity

Under Clause 3 of the 1950 Order, this profession resulted in the immediate loss of SC status, as Christianity is not one of the religions specified in the Order

The Court rejected the Appellant’s reliance on State Government Order (G.O. Ms. No. 341), clarifying that executive orders can only grant non-statutory concessions and cannot override Presidential Orders or extend statutory SC status to converts

The Court further distinguished Scheduled Tribes (ST) from SCs, noting that the Constitution (Scheduled Tribes) Order, 1950 does not contain a religion-based bar, whereas the SC Order does

Regarding the IPC counts (Sections 341, 506, 323), the Court noted that the testimony of witnesses was inconsistent, the medical evidence showed only simple injuries, and no independent witness corroborated the specific overt acts attributed to the Respondents

The IPC charges were quashed because the investigation material failed to provide a basic foundation for the alleged offences, rendering the continuation of the trial an abuse of the process of law

The Supreme Court dismissed the appeal and upheld the High Court’s decision to quash the proceedings