Caste status after reconversion can revive where the community accepts the person and no caste usage bars readmission.
Conversion to Christianity does not invariably and permanently extinguish original caste status under the Constitution (Scheduled Castes) Order, 1950. Where the caste's structure and usage permit readmission, and the community in fact accepts the person after reconversion to Hinduism, original caste membership may revive for Scheduled Caste purposes. On the evidence, repeated community recognition, participation in caste and temple functions, treatment of the children as Adi Dravida Hindus, and a special conference for readmission showed actual acceptance by the Adi Dravida community. The respondent therefore satisfied the relevant constitutional requirements for reserved-seat eligibility, and the challenge to his status failed.
Issues: (i) whether a person who has converted to Christianity and later reconverted to Hinduism can regain membership of his original caste if the caste accepts him, and (ii) whether the evidence established that the respondent had in fact been accepted as a member of the Adi Dravida caste so as to be qualified for the reserved seat.
Issue (i): whether a person who has converted to Christianity and later reconverted to Hinduism can regain membership of his original caste if the caste accepts him
Analysis: The scheme of the Constitution (Scheduled Castes) Order, 1950, read with Articles 341 and 366(24) of the Constitution of India, does not support an absolute rule that conversion to Christianity permanently extinguishes caste membership in every case. The decisive consideration is whether, having regard to the structure and usage of the caste, the community continues to treat the convert as within its fold after reconversion to Hinduism. The legal test is a practical one: if the caste accepts the person and no rule or usage bars readmission, reconversion may restore the original caste status.
Conclusion: Yes. On reconversion to Hinduism, the person can again become a member of the original caste if accepted by the caste community.
Issue (ii): whether the evidence established that the respondent had in fact been accepted as a member of the Adi Dravida caste so as to be qualified for the reserved seat
Analysis: The evidence relied upon by the High Court showed repeated recognition of the respondent by Adi Dravida Hindus in community and temple functions, participation in caste-related affairs, treatment of his children as Adi Dravida Hindus, and a special conference convened to readmit him into the fold. These circumstances, taken together, were sufficient to establish actual acceptance by the caste community. Once such acceptance was proved, and the respondent was professing Hindu religion, he satisfied the requirements of Paragraphs 2 and 3 of the Constitution (Scheduled Castes) Order, 1950.
Conclusion: Yes. The respondent was accepted as an Adi Dravida and was qualified as a Scheduled Caste candidate at the material time.
Final Conclusion: The rejection of the respondent's nomination was not established, and the election of the appellant was liable to be set aside. The appeal failed.
Ratio Decidendi: Conversion to Christianity does not invariably and permanently sever caste membership; where the caste's structure and usage permit readmission and the community in fact accepts the convert on reconversion to Hinduism, original caste status may revive for the purposes of Scheduled Caste qualification.
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