In a significant judgment, the Supreme Court of India on November 26, 2024, dismissed the appeal of C. Selvarani, who sought recognition as a member of the Scheduled Caste (SC) category despite being baptized as a Christian. The Court ruled that Selvarani’s religious status as a Christian disqualifies her from receiving the benefits reserved for Scheduled Castes under the Constitution (Pondicherry) Scheduled Castes Order, 1964.
The verdict, delivered by Justice Pankaj Mithal and Justice R. Mahadevan, clarified that an individual professing Christianity cannot claim SC status, emphasizing the importance of preserving the integrity of the reservation system.
The Case at a Glance
The appeal, registered as Civil Appeal No. ___ of 2024 (arising out of SLP (C) No. 6728 of 2023), was brought before the Supreme Court after Selvarani’s earlier plea in the Madras High Court was dismissed. Selvarani had sought to quash orders by the government authorities in Puducherry that denied her a Scheduled Caste certificate.
The appellant argued that she belonged to the Valluvan caste, listed as a Scheduled Caste under the 1964 Presidential Order, and had been treated as such throughout her education. However, during a background check for her government job application under the SC category, discrepancies surfaced, revealing her baptism and continued adherence to Christian practices.
Key Legal Issues
1. Eligibility for SC Benefits:
Under Article 341 of the Indian Constitution, SC recognition is restricted to individuals practicing Hinduism, Sikhism, or Buddhism. The law explicitly excludes Christians from the SC category to maintain the benefits for the socio-economically disadvantaged groups within these religions.
2. Caste Revival Post-Conversion:
The appellant argued that caste, being a birthright, remains dormant or “eclipsed” upon conversion to another religion and can revive upon reconversion. She cited prior Supreme Court decisions supporting this notion. However, the Court found no evidence of genuine reconversion to Hinduism or acceptance by the Valluvan caste.
3. Fraud on the Reservation System:
The Court condemned attempts to misuse reservation benefits. It observed that any claim to SC benefits by an individual who actively practices Christianity undermines the constitutional ethos of reservation and denies rightful beneficiaries their opportunities.
Facts of the Case
Selvarani was born in 1990 to a Hindu father and Christian mother in Puducherry. While she claimed that her mother converted to Hinduism after marriage, official records indicated that Selvarani was baptized as a Christian and actively participated in church activities. Her application for an SC certificate, required for her government job, was denied by Puducherry authorities citing her Christian faith.
Despite earlier possession of an SC certificate, an inquiry revealed contradictions. The family’s religious practices, including baptism records and participation in church activities, led to the rejection of her claim. Further appeals to higher administrative authorities and the High Court of Madras were dismissed before the case reached the Supreme Court.
Supreme Court’s Observations
The Supreme Court upheld the rejection of Selvarani’s claim, emphasizing:
– Clear Legal Boundaries: Quoting the Constitution (Pondicherry) Scheduled Castes Order, 1964, the Court stated that SC benefits are available only to individuals professing Hinduism, Buddhism, or Sikhism. Converts to Christianity are explicitly excluded.
– Lack of Evidence for Reconversion: The Court noted the absence of any public declaration, formal ceremony, or acceptance by the Valluvan caste community to substantiate Selvarani’s claim of reconversion.
– Fraudulent Misrepresentation: The Court stressed that dual claims of Christianity for religious practices and Hinduism for reservation benefits amounted to fraud. “The conferment of Scheduled Caste communal status to a Christian by religion but claiming to be Hindu for benefits goes against the object of reservation and would amount to a fraud on the Constitution,” it observed.
