The Chhattisgarh High Court recently observed that mass conversion of tribals to Christianity was leading to tension, social boycotts and sometimes even violence [Digbal Tandi v. State of Chhattisgarh].

A Division Bench of Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru noted that induced religious conversion of poor and illiterate tribal and rural populations has generated a particular controversy. While acknowledging that the Constitution guarantees the right to propagate a religion, the Court flagged its misuse through coercion, inducement or deception.

The phenomenon of mass or motivated conversions not only disturbs social harmony, but also challenges the cultural identity of indigenous communities, the Court opined.

The Court remarked that over time, missionary activity in India has become a platform for proselytization.

“Among economically and socially deprived sections, especially Scheduled Tribes and Scheduled Castes, this led to gradual religious conversion under the promise of better livelihoods, education, or equality. What was once seen as service became, in many cases, a subtle instrument of religious expansion. The menace arises when conversion ceases to be a matter of personal faith and becomes a result of inducement, manipulation, or exploitation of vulnerability. 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. This process has also led to deep social divisions within tribal communities,” the Court added.

Commenting further on the consequences of conversion of members of tribal communities, the Court said,

“Conversion disrupts this organic connection. The erosion of tribal faiths often results in the loss of indigenous languages, rituals, and customary laws. Moreover, newly converted individuals sometimes face rejection from their original community, creating social isolation and fragmentation. Furthermore, religious conversion can also influence political representation. Since certain constitutional benefits, such as Scheduled Tribe or Scheduled Caste status, are linked with religion, conversion may alter demographic patterns and political equations, adding another layer of complexity."

The Court said that India’s secular fabric thrives on coexistence and respect for diversity. However, it added that religious conversion is a legitimate exercise of conscience only when it is voluntary and spiritual.

“When it becomes a calculated act of exploitation disguised as charity, it undermines both faith and freedom. The so-called “conversion 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,” the Court said.

The High Court made these observations while dealing with a batch of petitions alleging prohibition of entry of Christians into various villages.

The Court was told that at least eight villages of Kanker District have erected hoardings which say that the entry of pastors and "converted Christians" is prohibited in the village.

It noted that the hoardings were installed by Gram Sabhas in exercise of their powers under Panchayat (Extension to Schedule Area) Act, 1996, following a circular of the State government. It, however, found that the circular did not authorise any discrimination. 

With regard to the hoardings, the Court said that they only restrain entry for conversion activities. It termed the apprehension that Christians in general have been banned from the villages as being “unfounded”.

The hoardings appear to have been installed by the concerned Gram Sabhas as a precautionary measure to protect the interest of indigenous tribes and local cultural heritage, the Court added. 

“The expression “right to propagate religion” under Article 25 of the Constitution…does not extend to converting another person through inducement, force, or fraudulent means. The Act of 1968 prohibits such activities. Therefore, a general cautionary hoarding intended to prevent illegal conversion activities cannot, per se, be termed unconstitutional,” it reasoned.

Thus, the Court declined relief to the petitioners. However, it said that they can avail an alternative remedy by approaching the Gram Sabha and then file an appeal before the sub-divisional officer (Revenue).

“Further, in case the petitioners have any apprehension that they would be restrained from entering their villages or any threat perception exists, they may seek protection from the police." 

Advocates Kishore Narayan, Arpit Lall and Ayush Lall represented the petitioners.

Additional Advocate General YS Thakur appeared for the State.

Advocates Sangharsh Pandey, Anupam Dubey, B Gopa Kumar, Himanshu Pandey, Palash Tiwari, Rohit Sharma, Harshal Chouhan, Mahesh Kumar Mishra, Vaibhav P Shukla, Vivek Kumar Agrawal and Jay Singh appeared for other respondents.

[Read Judgment]