Pastor’s Complaint Quashed as Court Holds Protective Legislation Not Applicable to Converted Christians
In a notable decision concerning the intersection of caste identity and religious conversion, the Andhra Pradesh High Court has ruled that individuals who convert from Hinduism to Christianity are no longer entitled to the protections offered under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The ruling was passed by Justice Harinath N in the case of Akkala Ram Reddy v. The State of Andhra Pradesh, decided on April 30, 2025.
The Court held that the very foundation of the SC/ST Act rests on the existence of caste-based discrimination, which is incompatible with the tenets of Christianity. Since caste is considered alien to Christianity, the protection under the Act cannot extend to individuals who have voluntarily converted to the religion.
Background of the Case
The judgment arose from a petition seeking the quashing of criminal proceedings initiated against a group of individuals accused of using casteist slurs and assaulting a Christian pastor, who was originally from a Scheduled Caste background. The FIR was registered under various provisions of the SC/ST Act and sections of the Indian Penal Code (IPC).
The complainant, identified as a pastor, had converted to Christianity over a decade ago and had been actively serving in a church for at least ten years prior to the alleged incident.
Key Observations of the Court
Justice Harinath N emphasized that only persons who continue to belong to a Scheduled Caste or Scheduled Tribe under the Constitution are entitled to invoke the SC/ST Act. The act of voluntary conversion to Christianity implies a relinquishment of the caste identity that forms the basis for protection under the legislation.
“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 said.
The Court went further to clarify that even if the complainant retained a caste certificate, the mere fact that it had not been formally cancelled did not entitle him to protection under the SC/ST Act post-conversion.
“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 2nd respondent has ceased to be a Member of the Scheduled Caste Community, the day he had converted to Christianity,” the Court stated.
False Complaint and Lack of IPC Offences
Upon reviewing the facts, the Court concluded that the criminal complaint appeared to be motivated and baseless. It found that the allegations under both the SC/ST Act and the Indian Penal Code lacked sufficient evidentiary support.
“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,” the Court held, granting the petitioners relief by quashing the proceedings entirely.
Representation of Parties
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For Petitioners: Advocate JV Phaniduth
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For Complainant-Pastor: Advocate Satheesh Kumar Eerla
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For State: Public Prosecutor
Legal Significance
This judgment adds to a growing line of judicial reasoning that evaluates the applicability of protective caste-based legislation in the context of religious conversion. The verdict reiterates the principle that the socio-legal identity conferred by caste does not transfer once an individual adopts a religion that does not recognize caste, such as Christianity or Islam.
While the issue remains contentious—particularly in light of differing sociological realities and the persistence of caste-based discrimination even among converts—this decision reinforces a strict interpretation of the SC/ST Act based on religious identity post-conversion.
