'Conversion By Inducement A Social Menace': Chhattisgarh High Court Upholds Hoardings Barring Entry Of Pastors, Converts In Tribal Villages

Expressing concern at certain missionary groups accused of religious conversion especially in remote tribal areas in Chhattisgarh, allegedly targeting illiterate and impoverished families, the Chhattisgarh High Court remarked that "conversion by inducement" by such groups is a "social menace". 

In doing so the court observed that this menace arises when conversion ceases to be a matter of personal faith but becomes a result of "inducement, manipulation, or exploitation of vulnerability". 

The court passed the order while upholding the action of the Gram Sabha in erecting 'hoardings/notice boards' at certain village entry points whereby the entry of Christian Pastors and converted Christians was barred, purportedly to prevent religious conversion of villagers through coercion or inducement.

Motivated conversion is against cultural identity of indigenous persons

Observing that religious conversion has long been a sensitive issue in India's sociopolitical landscape, a division bench of Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru said:

"Among the various forms of conversion, those allegedly carried out by Christian missionaries among poor and illiterate tribal and rural populations have generated particular controversy. While the Constitution guarantees every citizen the freedom to profess, practice, and propagate religion, the misuse of this liberty through coercion, inducement, or deception has become a matter of grave concern. The phenomenon of mass or motivated conversions not only disturbs social harmony but also challenges the cultural identity of indigenous communities. Missionary activity in India dates back to the colonial period, when Christian organizations established schools, hospitals, and welfare institutions"

The court said that initially, these efforts were directed at social upliftment, literacy, and health care; however, over time, "some missionary groups" began using these platforms as avenues for proselytization.

Induced conversions amounts to cultural coercion

It further said:

"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. Tribals converted to Christianity often adopt new cultural practices, distancing themselves from traditional rituals and communal festivals. As a result, villages become polarized, leading to tension, social boycotts, and sometimes even violent clashes".

Conversion by inducement social menace

The court said that Article 25 of the Constitution ensures the freedom of religion, but this right is not absolute. It referred to various states which had enacted anti conversion laws to prevent the misuse of this right. 

"The challenge lies in balancing religious freedom with the protection of cultural and social integrity. For many tribal groups, religion is intertwined with their ancestral traditions and ecological worldview. Conversion disrupts this organic connection. The erosion of tribal faiths often results in the loss of indigenous languages, rituals, and customary laws...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...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 court thus said that the remedy lies not in intolerance, but in ensuring that faith remains a matter of conviction, not compulsion.

Background

A number of Gram Sabhas had fixed certain hoardings disallowing entry of Christian Pastors and converted Christians into such villages coming under the district of Kanker. They proclaimed to be villages covered under the Fifth Schedule of the Constitution where the Panchayat (Extension to Schedule Area) Act, 1996 ('the PESA Act') is applicable.

The petitioners,practising Christians, had reasons to believe that erection of such hoardings have been done at the instance of the governmental authorities. Such apprehension stems from a circular issued by the Director, Panchayat on 14.08.2025, which asked Chief Executive Officers (CEOs) of the Zila Panchayats coming under the PESA Act to circulate a resolution/oath to protect “Jal, Jangal, Jameen” (water, forest and land). They alleged that such resolution resulted in installation of such hoardings.

It was further submitted that though Rule 40(A) of the Chhattisgarh Panchayat Upbandh (Anusuchit Kshetron par Vistar) Niyam, 2022 ('PESA Rules') empowers Gram Sabha to maintain peace in village but the same is subject to the provisions of the Constitution. It was their contention that Gram Sabha resolutions and the village hoardings restricting the entry of Pastors and the converted Christians violate Article 25 of the Constitution so also their freedom of movement throughout the country, which is guaranteed under Article 19(1)(d).

On the other hand, the State defended the impugned action by referring to the PESA Act and the PESA Rules which give ample powers to village bodies/Gram Sabhas to protect the cultural heritage and preserve traditional identities of villages. Reliance was also placed on the Madhya Pradesh Dharma Swatantrya Adhiniyam, 1968 ('the 1968 Act') which prohibits religious conversion by use of force or allurement or by fraudulent means.

The judgment of the Apex Court in Rev. Stanislaus v. State of Madhya Pradesh & Ors. (1977) was cited wherein the constitutional validity of the 1968 Act was upheld. Ergo, it was the vehement argument of the State that erection of such hoardings is in consonance with a legislation which has passed the muster of even the highest Court. Thus, it submitted, there is no violation of fundamental right by the actions of the Gram Sabhas.

Findings

The Court said Article 25 of the Constitution, which ensures the freedom of religion, is not absolute. Acknowledging the potential misuse of this right, the Supreme Court, in Rev. Stanislaus (supra) had upheld the constitutional validity of anti-conversion laws, ruling that the right to “propagate” one's religion does not include the right to convert another person.

The Gram Sabha, the Bench further held, is a constitutionally recognized body under the PESA Act and has been conferred with the powers to safeguard tribal traditions. Hence, it was of the considered view that a “general cautionary hoarding” intended to prevent illegal conversion activities cannot, per se, be termed unconstitutional.

“In view of the above observations made by the Apex Court, the installation of the hoardings for preventing forcible conversion by way of allurement or fraudulent means cannot be termed as unconstitutional. The hoardings appears[sic] to have been installed by the concerned Gram Sabhas as a precautionary measure to protect the interest of indigenous tribals and local cultural heritage.”

Disposing of the pleas, the court granted liberty to the petitioners to avail alternative remedy available under the PESA Rules, if they wish so.

"In case the petitioner or any individual apprehend threat to life, liberty, or movement, they may seek protection from the jurisdictional police, which shall be considered in accordance with law," the bench added. 

Case title: Digbal Tandi v/s State of Chhattisgarh

WPPIL No. 83 of 2025 and connected petition

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