Prayagraj: In a far-reaching order that could have significant administrative and political implications across Uttar Pradesh, the Allahabad High Court has directed a statewide investigation to ensure that individuals who have converted to Christianity are not wrongfully availing benefits reserved exclusively for Scheduled Castes (SC). Calling such practices a “fraud on the Constitution”, the Court set a strict four-month deadline for all District Magistrates (DMs) in the state to act in accordance with the law and submit compliance reports.
The order, passed by Justice Praveen Kumar Giri, came while the Court was hearing a plea filed by one Jitendra Sahani, an accused in a case involving allegations of religious conversion, derogatory remarks against Hindu deities, and the promotion of enmity between communities. Sahani had sought the quashing of the charge sheet and cognizance order issued against him under Sections 153A and 295A of the Indian Penal Code. However, the High Court not only dismissed his application but also highlighted serious inconsistencies regarding his professed religion, which ultimately led to the much broader set of directions.
The trigger for the Court’s sweeping intervention emerged when the State’s counsel pointed out stark contradictions in Sahani’s statements. Although Sahani claimed to be a Hindu in the affidavit filed before the Court, the police investigation revealed that he had converted to Christianity and was functioning as a Padri (priest). A witness statement recorded under Section 161 CrPC stated that Sahani, originally belonging to the Kewat community (a Scheduled Caste), had been actively engaged in preaching Christianity in the region.
The witness also alleged that Sahani would gather villagers and use abusive and mocking language about Hindu deities, encouraging them to shift to Christianity by offering assurances of jobs, business benefits, and financial support from “missionaries”. The High Court reproduced these allegations in its order, noting that they were serious enough to justify investigation but also served as a basis to examine the misuse of SC status after religious conversion.
Justice Giri underscored that the Constitution (Scheduled Caste) Order, 1950, makes it unequivocally clear that no person who professes a religion other than Hinduism, Sikhism, or Buddhism can be deemed a member of a Scheduled Caste. Paragraph 3 of the Order forms the core of the Court’s reasoning.
The bench observed that Sahani’s claim to belong to the SC category, despite being a Christian priest, could amount not only to a constitutional violation but also to forgery and deliberate misrepresentation.
In strengthening its conclusion, the High Court relied heavily on the Supreme Court’s judgment in C. Selvarani v. Special Secretary-cum-District Collector (2024), where the apex court had categorically held that an individual automatically ceases to belong to their original caste after converting to Christianity.
The Supreme Court had further noted that conversion undertaken solely to avail reservation benefits is nothing but a fraud on the Constitution and runs contrary to the spirit of affirmative action policies. By quoting this decision, the Allahabad High Court reinforced that caste identity is inextricably linked with the religious traditions under which caste originated.
The bench also cited the Andhra Pradesh High Court’s 2025 ruling in Akkala Rami Reddy v. State of A.P., which held that a person actively practicing Christianity cannot invoke protections under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act.
In light of these findings, the Allahabad High Court issued a series of strong directives to ensure that “the law is implemented in its true sense” across Uttar Pradesh.
The Court ordered; the Cabinet Secretary (Government of India) and the Chief Secretary of Uttar Pradesh, to review the legal framework governing Scheduled Caste benefits and ensure strict adherence to constitutional principles.
Further, the Principal Secretary of the Minorities Welfare Department was instructed to take appropriate steps to eliminate confusion or misuse regarding the overlap between minority status and SC status.
However, the most significant direction was aimed at all District Magistrates (DMs) in Uttar Pradesh, who have been asked to:
- conduct a thorough inquiry into individuals who have converted to Christianity but continue to retain SC certificates,
- act strictly in accordance with the Constitution (SC) Order, 1950, and
- submit compliance reports to the Chief Secretary within four months.
The Court emphasized that this exercise is essential to prevent a “fraud on the Constitution”, echoing the Supreme Court’s language.
Apart from the general directions, Justice Giri instructed the District Magistrate of Maharajganj to conduct a detailed inquiry into Sahani’s religious status within three months. If it is found that he falsely declared himself Hindu in court documents despite being a Christian priest, strict action is to be initiated for forgery and misrepresentation.
Although the Court dismissed Sahani’s application, it clarified that he remains free to file a discharge application before the trial court and raise all legal objections, including the claim that Sections 153A and 295A IPC are not attracted based on the evidence collected.
Legal experts believe the order could result in one of the most extensive administrative exercises in recent years on the issue of reservation misuse. By extending the scrutiny statewide and mandating top-level bureaucratic oversight, the Court has signaled zero tolerance for misrepresentation of caste identity after religious conversion.
