Scheduled Tribe status after conversion depends on continued tribal identity and customs, not automatic loss.

Scheduled Tribe status under Article 342 is not automatically lost on conversion; the decisive question is whether the person and family continue to be accepted as part of the tribe and whether tribal customs, traits, and social and family laws remain observed. That inquiry is fact-specific and cannot be answered in the abstract, and executive circulars cannot override the constitutional scheme under Article 13. On the stated facts, the issue whether the victim's family had ceased to belong to the notified tribe required trial, so quashing the proceedings at the threshold was not justified.

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Issues: Whether conversion to another religion by a person or his family automatically causes loss of Scheduled Tribe status, and whether the quashing of proceedings under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act was justified without trial.

Analysis: The constitutional scheme under Article 342 makes Scheduled Tribe status dependent on the Presidential notification and the social and customary attributes of the community. A person does not necessarily cease to be a member of a tribe merely because of conversion; the decisive inquiry is whether the person continues to be accepted as part of the tribe and whether tribal customs, traits, and customary laws of marriage, succession, inheritance, and social life continue to be observed. That inquiry is fact-specific and cannot be answered in the abstract. The Court also held that executive circulars cannot determine legal status under Article 13. On the facts, whether the victim's family had ceased to be members of the notified tribe could be decided only at trial, and the High Court erred in quashing the charge at the threshold.

Conclusion: Conversion by itself does not automatically terminate Scheduled Tribe status; the issue depends on evidence of continued tribal identity and customs, and the proceedings could not have been quashed without trial.

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