The Allahabad High Court has directed a statewide probe across Uttar Pradesh to ensure that persons who have converted to Christianity do not continue to avail benefits reserved for Scheduled Castes (SC). The court observed that retention of SC status after conversion amounts to a “fraud on the Constitution,” and therefore instructed the entire administrative machinery in the State to act swiftly. All District Magistrates in Uttar Pradesh have been given a four-month deadline to identify and prevent instances where converted individuals illegally retain SC status.
This decision came during the hearing of a quashing plea filed by Jitendra Sahani, who had challenged chargesheet and cognizance orders under Sections 153-A and 295-A of the Indian Penal Code (IPC). In his plea, Sahani had claimed he was only seeking permission to preach Christianity on his land and alleged that the charges were false. However, the State’s submission before the Court revealed a contradiction: while Sahani had declared himself as “Hindu” in his affidavit, police investigation and witness statements showed that he had converted to Christianity and was functioning as a “Padri” (priest). It was further alleged that he had mocked Hindu deities and religious practices, disparaged caste-based aspects of Hinduism, and promised ill-informed Hindu villagers better socio-economic opportunities — such as jobs and business growth — if they embraced Christianity.
The Court took serious note of these allegations. It reproduced the relevant witness testimony in its order, which stated that Sahani, originally from the “Kewat” community, had gathered villagers and used abusive and insulting language about Hindu gods to influence them towards conversion. The witness detailed Sahani’s derogatory remarks — including references to multiple gods with bizarre descriptions — and his claim that embracing Christianity would provide material benefits, while Hinduism offered only caste-based oppression.
Invoking the legal framework, the Court referred to the Constitution (Scheduled Castes) Order, 1950, under which SC status is restored only to persons professing Hindu, Sikh or Buddhist faiths. It cited that as per Paragraph 3 of the Order, persons professing any other religion — including Christianity — cannot be deemed members of Scheduled Castes. The bench also relied heavily on a recent verdict by the Supreme Court of India in C. Selvarani v. Special Secretary-cum-District Collector (2024), wherein the apex court held that an individual loses SC status upon conversion to Christianity. That judgment had described conversions effected solely to avail reservation benefits — without genuine religious belief — as a “fraud on the Constitution.” In addition, the Court referred to a 2025 decision by the Andhra Pradesh High Court in Akkala Rami Reddy v. State of A.P., where it was held that individuals who convert to Christianity and actively practice the religion cannot continue to claim SC status or invoke protections under the SC/ST (Prevention of Atrocities) Act.
Given these jurisprudential precedents, the Allahabad High Court concluded that the retention or claim of SC status by Christian converts undermines the constitutional scheme of reservations and equality. Hence, it issued comprehensive directions: The highest executive authorities — the Cabinet Secretary of the Government of India, the Chief Secretary of Uttar Pradesh, and the Principal Secretary of the Minorities Welfare Department — have been entrusted with the responsibility to ensure that the distinction between minority status and Scheduled Caste status is strictly enforced.
For the particular applicant, Sahani, the Court ordered a detailed enquiry by the District Magistrate of Maharajganj into his religion within three months. If the enquiry finds that he indeed misrepresented his religion — filing an affidavit claiming Hindu faith while functioning as a Christian priest — the Court directed that strict action be taken for forgery and misuse of the judicial process to prevent recurrence of such false affidavits. Meanwhile, the quashing plea filed by Sahani was dismissed. However, the Court permitted him to file a discharge application before the trial court, allowing him to raise any grievances such as absence of required ingredients under the charged IPC sections.
By issuing these sweeping instructions and emphasising the constitutional and legal imperatives, the Allahabad High Court has signaled that religious conversion cannot be used as a tool to exploit reservation benefits, and that the identity and benefits attached to Scheduled Caste status must align with genuine religious and constitutional eligibility.
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