Chhattisgarh: As Supreme Court Backs Posters Banning Entry of 'Converted Christians', Where Are the Gram Sabha Orders?

New Delhi: On February 16, the Supreme Court dismissed a petition that challenged an October 2025 ruling of the Chhattisgarh high court. The ruling had stated that billboards banning the entry of priests and "converted Christians" in eight villages of Kanker district of the state were "not unconstitutional."

In mid-June 2025, posters and hoardings were put up in various tribal regions of Kanker district, Chhattisgarh, prohibiting the entry of Christian priests and "converted Christians".

According to the petition submitted to the high court, Gram Sabha meetings took place in Kudal village on June 25, 2025, and in Parvi village on June 26, 2025. It was claimed in the petition that resolutions were passed to prohibit the entry of Christian priests into the villages after the meetings.

Starting from the second week of August 2025, large boards and hoardings began to be put up in several villages in Kanker district. These posters stated that the villages in question fall under the Fifth Schedule and, therefore, under the Panchayat (Extension to Scheduled Areas) Act, 1996 (PESA), and so the Gram Sabhas of these villages have the right to safeguard their culture, traditions, and identity. In light of this, the posters proclaimed that Christian priests and "converted tribal Christians" were barred from entering the villages.

Interestingly, no copy of the resolution referencing this hasty action is available in the district panchayat records.

Poster in Patharrinara village. Photo: By arrangement.

According to the petition, hoardings were put up in at least eight villages: Kudal, Parvi, Junwani, Ghota, Ghotia, Havenchur, Musurputta, and Sulangi. Some posters also stated that tribal people were being converted through various inducements, thus jeopardizing the traditional culture and social framework of the village. In response to this perceived threat, priests and "converted Christians" from neighbouring villages were barred from entering the village.

The petition further stated that these directives affected not only outsiders but also Christian families residing in the same villages, who experienced social ostracism and pressure.

'Fear among the Christian community'

Petitioner Digbal Tandi made serious allegations regarding the impact of these posters on the ground. Tandi, a resident of Kanker district, filed a public interest litigation in the Chhattisgarh high court on September 10, 2025. He asserted that following the installation of the posters, priests were not only restricted from visiting other villages, but in many cases, were even barred from entering their own villages.

The petition states that these restrictions have directly impacted the religious activities of the Christian community. In numerous villages, prayer meetings were disrupted, and Christian families faced social pressure, fear, and ostracism.

The petitioner informed the court that these posters fostered an atmosphere of fear within the Christian community, leading them to refrain from visiting villages they previously frequented due to concerns over untoward incidents or violence.

The petition further stated that these hoardings violated the freedom of religion of Christian citizens and their right to move freely within the country. The petitioner contended that this is not only a matter of religious freedom, but also of civil dignity and security.

The petitioner also argued that the Gram Sabha possesses the right to safeguard matters and traditions related to water, forests, and land under the PESA Act. However, this right does not supersede a citizen's fundamental rights. The petition clearly explicitly stated that barring a person from entering the village solely on the basis of their religion violates Article 14 (equality), Article 19(1)(d) (freedom of movement), and Article 25 (freedom of religion) of the Constitution.

The relief sought from the high court in the petition are as follows:

(i) All relevant records related to the case should be summoned.

(ii) The hoardings put up in the villages be declared unconstitutional, illegal and violative of the fundamental rights guaranteed under Articles 25 and 19(1)(d) of the Constitution of India.

(iii) The respondent parties be directed to remove the above-mentioned illegal hoardings.

(iv) The respondent authorities, particularly the Collector and Superintendent of Police of Kanker District, be directed to visit the villages where the above-mentioned hoardings have been put up and hold meetings with villagers/stakeholders to restore peace and harmony among various communities, so as to instill a sense of security among the Christian community in Kanker District.

Hoarding in Ghotia village. Photo: By arrangement.

Gram Sabha process, memorandum to the administration, and RTI

Digbal Tandi also alleged in the petition that the Gram Sabha resolutions cited in the posters in several villages were passed without following the prescribed legal process. On Havenchur village, the petition stated that no announcement was made on the Gram Sabha meeting there, and local residents were unaware that such a meeting had taken place.

The petitioner asserted that in certain instances, decisions were enforced in the name of the Gram Sabha, which were later implemented as decisions of the entire village.

Following these incidents, on August 11, 2025, Digbal Tandi, along with other citizens, submitted a written memorandum to the District Collector, Superintendent of Police, and Sub-Divisional Officer of Kanker. The memorandum demanded action against the resolutions purportedly passed by the Gram Sabhas and the posters put up based on them.

It stated that these resolutions were arbitrary, discriminatory, against democratic values, and an abuse of the powers granted to Gram Sabhas under the PESA Act.

The petition further alleged that the government machinery might be involved in the placement of these hoardings. To substantiate this argument, the petitioner cited a circular issued by the Director of Panchayats on August 14, 2025, which directed the Chief Executive Officers of District Panchayats in districts where PESA was in force to administer an oath in Gram Sabhas regarding the protection of "water, forest, land," and cultural heritage.

As stated in the petition, before this circular was issued, some individuals associated with the ruling party instigated tribal villagers to put up such posters and used the PESA Act to spread religious hatred against the Christian community.

Gram Sabha order cited untraceable

On August 27, 2025, Digbal Tandi sought information from the District Panchayat, Kanker, under the Right to Information (RTI) Act, whether any Gram Sabha had officially passed a resolution banning the entry of Christian priests or Christians.

The response received on October 13, 2025, stated that no such resolution was recorded in the District Panchayat's documents. The petition stated that despite this, posters continue to be displayed in the villages and restrictions are being imposed based on them.

The petitioner tried to acquire copies of the Gram Sabha resolutions from the Gram Panchayat. However, the request for copies was denied.

High court order and comments on conversion

After hearing the case, the Chhattisgarh high court, on October 28, 2025, did not issue any order to remove the posters or declare them unconstitutional. In its ruling, the High Court stated that the hoardings erected to deter forced conversions through inducement or fraud cannot be termed unconstitutional and appear to have been put up by the respective Gram Sabhas as a precautionary measure to protect the interests of tribal communities and the local cultural heritage.

The court also stated that the petitioners have alternative legal remedies available under the Chhattisgarh PESA Rules, 2022.

According to the court, the petitioners can approach the Gram Sabha under Rule 14(1) and, if they are still not satisfied, can appeal to the Sub-Divisional Officer (Revenue) under Rule 14(2). The court also stated that if the petitioners fear being prevented from entering the village or face any threat, they can seek police protection.

During the hearing and in its order, the high court made detailed observations regarding conversion. The court stated that religious conversion has long been a sensitive social and political issue in India, especially among poor, uneducated tribal and rural populations.

According to the court, when conversion becomes a matter of allurement, pressure, or exploitation rather than a matter of personal faith, it poses a threat to social harmony and the cultural identity of tribal communities. The court stated that such situations can lead to tensions, social exclusion, and sometimes even violent confrontations in villages.

'Posters are against fundamental rights'

Shalini Gera, a lawyer at the Chhattisgarh high court and a member of the PUCL, Chhattisgarh, stated that the posters put up in villages are a direct violation of fundamental rights.

She told The Wire Hindi, "Those posters are against fundamental rights. The PESA Act does not allow the Gram Sabha to pass any resolution that violates fundamental rights."

She stated that the manner in which these posters are being executed in practice is not merely theoretical. Violence against the Christian community is steadily on the rise.

Connecting this to a previously observed pattern, Gera said, "We've seen violence against Christians in the past. This is part of that trend. Therefore, it's highly regrettable that the high court ignored the social context surrounding these events."

Questioning the high court's characterisation of the posters as a "precautionary measure," she remarked, "The high court has said that it is merely a precautionary measure. But I fail to comprehend what it means to prevent. What precisely are they trying to prevent? The current situation is such that people attending church are literally being expelled from their homes."

She clearly asserted that fundamental rights must not be infringed upon under the pretext of safeguarding culture and tradition.

Petition filed in the Supreme Court and the current scenario

Challenging this high court order, the petitioner approached the Supreme Court. However, the Supreme Court also dismissed this special leave petition.

A bench of Justices Vikram Nath and Sandeep Mehta refused to interfere with the High Court order, stating that the High Court had given the petitioners the freedom to approach the statutory authority under the PESA Rules.

According to a LiveLaw report, Solicitor General Tushar Mehta, appearing for the state, argued that the scope of the petition filed before the High Court was limited. However, several new facts and aspects have been added during the Supreme Court petition, and therefore, the High Court can be approached again.

Senior advocate Colin Gonsalves, appearing for the petitioners, stated that the high court's comments regarding missionary activities in tribal areas were based on no concrete evidence. He also questioned why the petitioners were being asked to approach the Gram Sabha or any other authority.

Gonsalves also drew the court's attention to other pending cases, including those related to nearly 700 alleged attacks on pastors during prayer meetings and disputes over the funeral rites of tribal people who converted to Christianity. He also claimed that there has not been a single conviction in any conversion case in Chhattisgarh in the last 10 years.

Justice Vikram Nath remarked, "You should have approached the appropriate authority as per the rules, where the matter would have been investigated based on affidavits, materials, and evidence."

However, despite orders from both the Supreme Court and the high court, the case remains open to a fundamental question: whether the religious and constitutional rights of a citizen or community can be limited in the name of "protecting culture" under the PESA Act and the Fifth Schedule.

According to the allegations in the petition, these posters on the ground are still impacting the daily lives, religious activities, and social security of the Christian community.

Regarding the Supreme Court's advice to the petitioners to appeal under PESA, Shalini Gera pointed to the ground reality, stating that minority Christians in rural areas are already under pressure. Therefore, expecting them to appeal before the Gram Sabha is impractical.

"In the entire village, there are only one or two households that attend church, while the rest of the village is dominated by majoritarianism,” she said. “We have seen that the villagers do not even allow them to attend the Gram Sabha."

"In such a situation, asking them to file a petition means that the court is issuing such orders without taking into account the ground realities," she added.

Translated from the Hindi original, which first appeared on The Wire Hindi, by Naushin Rehman.

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