Context: 

Recently, the Allahabad High Court directed the Uttar Pradesh government to ensure that individuals who convert from a Scheduled Caste (SC) background to Christianity automatically forfeit reservation benefits linked to their SC identity. The directive was issued in a case involving Jitendra Sahani, accused of promoting religious enmity and allegedly misrepresenting his caste and religion in court documents.

Background of the Case:

• • The case involves Jitendra Sahani, booked under Sections 153-A (promoting enmity) and 295-A (insulting religious beliefs) of the IPC.
  • Allegation: Sahani, originally Hindu, had converted to Christianity, held prayer meetings, and allegedly made offensive remarks about Hindu deities.
  • FIR filed based on witness Lakshman Vishwakarma, who claimed Sahani mocked Hindu deities and encouraged villagers to convert for “economic benefit” and social respect.
  • Sahani, in court affidavit, described himself as a Hindu and claimed Scheduled Caste (SC) status, creating a contradiction.

Constitutional and Legal Framework on SC Status and Conversion:

• • Constitution (Scheduled Caste) Order, 1950 (Article 341):
    • Paragraph 3: “No person who professes a religion different from the Hindu, Sikh or Buddhist religion shall be deemed to be a member of a Scheduled Caste.”
    • Implication: Conversion to Christianity or Islam terminates SC status.
  • Article 366(24) of the Constitution:
    • Defines Scheduled Castes as groups notified under Article 341.
    • SC identity is legally inseparable from religion.
  • SC/ST (Prevention of Atrocities) Act:
    • Adopts same definitions, reinforcing that caste identity is tied to religion.

Judicial Precedents:

1.      Soosai v. Union of India (1986):

o    A Christian convert from a caste listed in 1950 SC Order is barred from SC status under Paragraph 3.

2.      C. Selvarani Case:

o    Upon baptism and conversion to Christianity, a person ceases to belong to their original caste.

o    Conversion done solely to claim reservation benefits is not permissible as it defeats the social purpose of reservation.

Allahabad High Court Observations:

• • The Court refused to quash the case against Sahani.
  • Concerned with inconsistent identities: accused described as Christian priest in FIR but claimed Hindu SC in court.
  • Held that Article 25 (religious freedom) does not allow maintenance of incompatible identities.
  •  Noted that retaining SC benefits post-conversion would amount to a “fraud on the Constitution.”
  • Directed that trial court must examine the discrepancy in religious and caste identity.

Significance of the Case:

• • Highlights the link between religion and SC status under Indian law.
  • Reaffirms Supreme Court precedents: conversion to Christianity/Islam ends legal SC identity.
  • Shows how reservation benefits are tied to constitutional classification and social policy, not merely claimed identity.
  • Impacts policy and administration: state authorities may need to verify SC/ST status in cases of religious conversion to prevent misuse.