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Supreme Court upheld the Chhattisgarh High Court ruling allowing tribal villages to use the PESA Act to ban missionaries, protecting indigenous culture from deceptive and forced conversions

There are moments in a nation’s journey when a quiet legal battle reflects a much deeper social churn. The debate around religious conversions in India has become one such moment. Many believe that the issue is no longer limited to cities or visible institutions. It has reached remote tribal belts, where communities say they are facing increasing pressure to abandon their traditional beliefs.
In several tribal villages of Chhattisgarh, residents claim that Christian missionaries have been approaching vulnerable families with offers of help and support, eventually urging them to convert. According to local accounts, these efforts are not always spiritual discussions but often involve inducements and persuasion aimed at poor and illiterate families.
Feeling cornered, some villages decided to act. Eight tribal villages in Kanker district, namely Habechur, Musurputta, Sulagi, Parvi, Junwani, Ghota, Ghotiya and Kudal, passed resolutions through their Gram Sabhas. They also installed hoardings in their Scheduled Areas warning against religious conversion activities. These boards stated that under the Panchayat Extension to Scheduled Areas Act, the entry of Christian priests and pastors was restricted.
The matter did not remain local. It reached the Chhattisgarh High Court and later the Supreme Court. A petition was filed by Digbal Tandi from Kanker district challenging these restrictions. However, both courts dismissed the plea.
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Supreme Court Supports High Court’s Position
On 16th February (Monday), a bench of Justices Vikram Nath and Justice Sandeep Mehta refused to interfere with the Chhattisgarh High Court’s judgment. The high court had made observations about conversions carried out through coercion and deceit and their impact on social harmony and tribal identity.
Senior counsel Colin Gonsalves represented Tandi. He argued that the high court had made broad and negative comments about Christian missionary work without supporting documents. He also maintained that the issue before the high court was limited and did not require such general remarks.
Gonsalves told the Supreme Court that another case involving more than “700 assaults” on pastors during prayer meetings was currently under consideration. He also referred to incidents where tribals who converted to Christianity were allegedly denied burial rights in their own hamlets. He further cited claims that the bodies of converted tribals buried in villages were being dug up. He added that in the past ten years, there had not been a single conviction under the state’s conversion law.
During arguments, he stated, “You can’t stop me from doing my Sunday prayer meeting and the high court says it’s not unconstitutional,” claiming that the remarks had wider implications.
On the other side, Solicitor General Tushar Mehta, representing the Chhattisgarh government, responded that many of the submissions made before the Supreme Court were not part of the original pleadings before the high court. He emphasized that the high court case was limited to the removal of hoardings and that the petitioners had been asked to approach the Gram Sabhas.
The bench agreed with this view. The judges clearly told Gonsalves, “Gonsalves, please see the writ petition before the high court and the relief claimed. You have been asked to go to the Gram Sabhas,” reinforcing that the issue had a narrow scope. The Supreme Court ultimately upheld the high court’s order and rejected the plea.
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High Court Protects Indigenous Tribal Interests
Earlier, on 28th October (Tuesday) of the previous year, the Chhattisgarh High Court had refused to stop the eight villages from putting up hoardings against forcible or fraudulent conversions. Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru ruled that placing such warning signs could not be considered illegal.
The petition had sought removal of the hoardings, claiming discrimination against Christian pastors and converts by restricting their entry. Tandi alleged that the Christian community was being separated from the rest of society.
The plea also accused the Panchayat Department of directing Zila, Janpad and Gram Panchayats to adopt a resolution titled “Hamari Parampara Hamari Virasat (Our tradition, our heritage),” which barred pastors and converted Christians from entering villages.
The court firmly responded, “No material has been placed on record to indicate that the circular authorises discrimination against any religious group,” rejecting the claim of bias. It further clarified that the hoardings did not show discrimination against Christians. They only restricted certain pastors from entering if they intended to conduct religious conversion programs.
The judges observed, “The hoardings appear to have been installed by the concerned Gram Sabhas as a precautionary measure to protect the interests of indigenous tribes and local cultural heritage.”
The high court also stated that the petitioner had not exhausted available statutory remedies before approaching the court. It reminded him, “A party must firstly exhaust the statutory alternative remedy available before approaching the high court seeking redressal of any grievance,” underlining procedural discipline.
Judges Raise Concerns About “Cultural Coercion”
In their detailed observations, the judges discussed the broader impact of large-scale conversions on tribal communities. They acknowledged that missionary activity in India dates back to the colonial era.
The court remarked, “Missionary activity in India dates back to the colonial period, when Christian organisations established schools, hospitals and welfare institutions. Initially, these efforts were directed at social upliftment, literacy and health care.”
However, the bench added, “However, over time, some missionary groups began using these platforms as avenues for proselytisation. Among economically and socially deprived sections, especially the Scheduled Tribes and the Scheduled Castes, this led to a gradual religious conversion under the promise of better livelihoods, education, or equality,” suggesting a shift in purpose over time.
The court expressed serious concern about what it termed “cultural coercion.” It noted, “In remote tribal belts, missionaries are often accused of targeting illiterate and impoverished families, offering them monetary aid, free education, medical care, or employment in exchange for conversion. Such practices distort the spirit of voluntary faith and amount to cultural coercion.”
The judges further observed, “This process has also led to deep social divisions within tribal communities, distancing them from traditional rituals and communal festivals. As a result, villages become polarised, leading to tension, social boycotts and sometimes even violent clashes.”
Religious Freedom and Its Limits
The high court clarified that Article 25 of the Constitution guarantees religious freedom but not without limits. It is subject to public order, morality and health. The bench emphasized that several states have enacted anti-conversion laws because the right can be misused.
The judges stated, “India’s secular fabric thrives on coexistence and respect for diversity. Religious conversion, when voluntary and spiritual, is a legitimate exercise of conscience. However, when it becomes a calculated act of exploitation disguised as charity, it undermines both faith and freedom,”
They added, “The so-called ‘conversions by inducement’ by certain missionary groups is not merely a religious concern. It is a social menace that threatens the unity and cultural continuity of India’s indigenous communities. The remedy lies not in intolerance, but in ensuring that faith remains a matter of conviction, not compulsion,”
Rising Conversion Concerns in Chhattisgarh
Chhattisgarh continues to face repeated allegations of forced or induced conversions. In December 2025, a prayer meeting in a village under Katghora police station in Korba district reportedly targeted sick individuals, childless couples and poor families. Locals complained that prayers were presented as cures and attendees were encouraged to convert for spiritual healing.
In another case last November, Hindu women and children were found participating in a Christian prayer meeting inside a house in Chilhati village near Sarkanda police station in Bilaspur district. Hindu activists later intervened. Kanhaiya Sahu claimed that a house on Shandi Mandir road was being used to attract Hindus towards Christianity.
Reports indicated more than 38 similar incidents across Civil Lines, Sarkanda, Koni, Sakri, Torwa, Masturi, Sipat and Pachpedi within six months. Two cases were registered in Sarkanda and Pachpedi police station areas on 12th November.
A new pattern also emerged involving female preachers known as “lady missionaries.” These women reportedly approached widows and economically weak women, inviting them to “Changai Sabhas” or healing prayer meetings. According to investigations, girls aged between 3 and 14 were also influenced during these gatherings. Forms were filled at churches, promising regular Sunday attendance and faith in divine healing. Improvements in health were often attributed to “the Lord’s blessings,” even when modern medicines were used.
Many converts reportedly retained their Hindu names and identities, allowing them to continue accessing caste-based reservations.
A June report that year highlighted a 41% increase in Christian population in several districts of Madhya Pradesh, Chhattisgarh and Rajasthan, especially in tribal belts, over the past decades.
The Broader Conversion Network
The Joshua Project, described as a Christian conversion research program, reportedly claimed that 24 lakh individuals were converted in 2024. It operates in Madhya Pradesh, Jharkhand, Odisha and Chhattisgarh, targeting 60 million individuals.
In Rajasthan’s Sri Ganganagar district, German nationals Swain Boz Bet Jaler and Sandra were arrested for allegedly offering money to encourage conversions. An unlicensed church was running from a rented house near the Pakistan border. Authorities reported derogatory remarks against Hindu deities during gatherings.
The couple’s visit to the sensitive Majhiwala border area triggered security alerts. Sri Karanpur, a region with strict foreign movement regulations, reportedly saw an unauthorised religious meeting organized by them.
These developments raise serious questions. Can a nation facing hostile borders afford unchecked religious networks in sensitive areas? Can religious liberty, already declared not absolute by courts, extend to practices that allegedly disturb social harmony?
Conclusion
If conversion through financial incentives and promises is defended as religious freedom, then communities that feel threatened may argue they too have the right to protect themselves. The debate is not only about faith but about identity, law and security.
When someone changes religion, separation in belief and cultural practice naturally follows. Whether that separation is personal or social remains contested. But the core question continues to echo across courtrooms and villages alike: where does freedom end and protection begin?
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