A bench of Justice Vikram Nath and Justice Sandeep Mehta declined to interfere with the High Court order, advising petitioners to seek remedies through statutory authorities instead.
BY PC Bureau
Februaru 17, 2026: The Supreme Court of India on February 16, 2026, dismissed a plea challenging restrictions on the entry of Christian missionaries and pastors into certain tribal villages in Chhattisgarh, effectively upholding a Chhattisgarh High Court order dated October 28, 2025. The ruling reinforces the authority of Gram Sabhas in Scheduled Areas to take measures aimed at protecting tribal communities from alleged forced religious conversions.
The case, Digbal Tandi vs. State of Chhattisgarh & Ors., arose from resolutions passed by Gram Sabhas in districts such as Kanker, where hoardings and notice boards were installed at village entrances. These notices barred Christian pastors, priests, and individuals who had converted to Christianity from entering, citing concerns over inducement, manipulation, and threats to social harmony and indigenous cultural identity. The restrictions were issued under the Panchayats (Extension to Scheduled Areas) Act, 1996 (PESA), which grants tribal Gram Sabhas the power to safeguard their customs, culture, and community resources.
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A bench comprising Justice Vikram Nath and Justice Sandeep Mehta declined to interfere with the High Court’s ruling. The bench noted that petitioners had already been granted liberty to approach the appropriate statutory authority under the PESA Rules or relevant state regulations to address specific grievances. The apex court also upheld the High Court’s broader observations that missionary work, while historically associated with education and healthcare, has in some instances shifted toward proselytization targeting economically and socially vulnerable tribal populations through promises of assistance, education, or social equality. Such activities, the High Court observed, could lead to social divisions, cultural disruption, and polarization in remote tribal regions.
Senior Advocate Colin Gonsalves, appearing for the petitioners, argued that the restrictions were overly broad and that the High Court had made sweeping generalizations about religious conversions without sufficient evidence. He contended that the prohibitions infringed upon constitutionally guaranteed freedoms. However, the Supreme Court found no grounds for intervention, emphasizing that precautionary or regulatory measures intended to address alleged illegal conversion activities do not automatically violate constitutional protections.
The ruling comes amid heightened tensions in tribal districts such as Bastar, Narayanpur, Kanker, and Kondagaon, where incidents of violence against pastors and Christian converts have been reported. These incidents are often linked to allegations of forced conversions by local groups and vigilantes. Chhattisgarh’s anti-conversion laws, along with protections under PESA, have intensified debates over the balance between religious freedom and safeguards against coercion. Article 25 of the Constitution guarantees the right to freely profess, practice, and propagate religion, but this right remains subject to public order, morality, and health.
The judgment underscores the ongoing tension between missionary outreach and tribal self-governance in Scheduled Areas. Supporters of the restrictions argue they are necessary to preserve indigenous traditions and cultural identity, while critics warn they may enable discrimination and undermine fundamental rights. The case also reflects broader national debates over anti-conversion laws, as similar legal challenges remain pending before the Supreme Court in several states.
