The author, Nandini Singh, is a second year student at Dr. Ram Manohar Lohiya National Law University, Lucknow.

Featured Artwork: The Observer Post

India overtook China in 2022 to become the most populous country. Presently, in 2024, it has a population of more than 1.44 billion. This population does not contain a homogenous group of people. Instead, it includes people from different religions, ethnicity, and caste. With such diversity comes an element of discrimination where one or more groups of people are discriminated against by the other members of the society. In this article, we will look into the discrimination due to the caste system prevalent in India. India’s caste system is the oldest social structure in existence. The group of people who have been oppressed the most due to this system are the ‘DALITS.’ Dalit means ‘crushed’ or ‘oppressed’ to an extent as to lose one’s original identity. Dalits in India have long faced oppression, discrimination, and humiliation because of the caste they were born in. To escape the social stigma and marginalization tied to their caste, many of them sought refuge in religions like Christianity and Islam. They saw conversion as an opportunity to become a part of an egalitarian religion and experience equality as promised by these religions. However, even after conversion, they are subjected to the same atrocities. Additionally, they have lost the privilege of reservation which was provided to the Schedule Caste as a form of reimbursement for the discrimination they faced. It has happened due to a provision in Part III of the Constitution (Scheduled Castes) Order, 1950, which lays down that no person who professes a religion different from Hinduism shall be deemed to be a member of the Scheduled Caste.

The effect of this order was that despite facing discrimination, the Dalit Christians and Muslims could not avail the benefit of reservation. The article will highlight the different reports and cases that have dealt with this issue and analyze the constitutionality of the 1950 Presidential Order. Analyzing the recent judgement of State Of Punjab And Ors. v Davinder Singh And Ors which laid down that SC can be sub-classified into creamy layer, the article will highlight how this judgement which laid down that criteria of socio-economic factors rather than religion should be used as basis to provide reservation in the case of Dalit converts to Christianity and Islam. This paper will conclude by providing the strategies and measures that should be taken through legislative and administrative changes to mitigate the problem.

Who are Dalit Converts?

 The Dalit community, also referred to as the “untouchables” in India and other South Asian nations, is a section of society that experiences lifelong marginalization, exclusion, and breaches of their human rights from birth. Since they are strictly “ranked” according to their descent, they are positioned at the bottom of society’s social strata. In order to save themselves from constant marginalization, Dalits choose to convert to other religions that have the capability to provide them with an equal environment. Therefore, Dalit converts are those who were Dalits first and then converted to different faiths. These converts are mainly of two faiths, Dalit Christians and Dalit Muslims, due to the ‘egalitarian nature’ of both of these faiths.

A 2008 report issued by the National Commission for Minorities states that the number of Dalit Muslims and Christians in the country is estimated at 32 lakh. The caste data it utilizes, however, is based only on responses from enumerators, who are not compelled to confirm the information they get, so this is an underestimate.

To emphasize the humanity and dignity of Dalits, the name “Christian Dalits ” was adopted instead of “Christians of scheduled caste origin” (CSCOs) or “harijan Christians.” Christian groups began calling Scheduled Castes “Dalits” in the late 1970s and early 1980s. The National Convention of the All India Catholic Union (AICU) later adopted the term “Dalit Christians” in 1989 to refer to Christians who were members of Scheduled Castes.

The Reality of Dalit Life after Conversion

When Dalits convert to a religion other than Hindu, they lose their reservation benefit. Many argue that this loss is overcome by the added advantage of transferring to an egalitarian religion. The reasoning appears to be that since Islam and Christianity are more equal faiths, a Dalit would not experience the same prejudice in their new faith. The main question that emerges is whether these converts have been saved from oppression by converting to these religions. And are Christianity and Islam, in reality, as caste-ridden as they are claimed to be?

The truth is far away from what is shown to be. Dalits converting to Islam and Christianity found that their “Dalitness” clung to them and followed them, even after their religious conversion. Numerous studies have shown that the social status of the Dalit community is unaffected by conversion to Christianity. John Webster claims that the Punjabi Dalit Christians offer an enlightening case study of an oppressed people who converted to obtain an “emancipatory identity” but ultimately found themselves the target of several massacres. The majority of Christians remain poor, landless laborers under the control of landlords and moneylenders, with little improvement in the circumstances surrounding their conversion. James Massey calls them the people facing three-fold discrimination[i]. First and foremost, they suffer from many forms of oppression, including social, economic, and political deprivation at the hands of so-called higher castes, in addition to being oppressed alongside Dalits who practice different religions. In addition, they experience discrimination on two other fronts: on the one hand, it comes from the government, and on the other hand, it comes from other Christians who identify as belonging to a higher caste.

Similarly, in the case of Dalit Muslim converts, according to a report, when asked about their experiences in upper-caste Muslim and Hindu homes, 13% of “Dalit Muslim” respondents said they had gotten food or water in different utensils in “upper-caste” Muslim homes. In upper-caste Hindu households, this percentage is around 46%. A quarter of “Dalit Muslims” reported having comparable experiences with upper-caste Hindus, and about a fifth of respondents thought that upper-caste Muslims kept their distance from them.

In the case of Indra Sawhney v Union of India it was noted by Hon’ble Justice P.B Sawant that, “when Islam and Christianity made their entries and ruled the country, many from lower castes embraced them to escape the tyranny and inequity. However, the change of religion did not always succeed in eliminating castes. The converts carried with them their castes and occupations to the new religion. The result has been that even among Sikhs, Muslims, and Christians, caste prevails in varying degrees in practice”.

The foundation of Indian society is the caste system forming a complete social and economic framework. Though the caste system has its roots in early Brahminical texts that are today referred to as “Hindu,” it has evolved over centuries to become ingrained in Indian society. It, therefore, has become a part of the Muslim and Christian religions. Although converting to any of these religions offers one access to a new theological community and set of beliefs, it is unable to alter one’s caste. Conversion cannot alter a person’s occupation, their possessions or lack thereof, their neighbors’ perception of them, or their social hierarchy. People who convert receive a new religious scripture and see a shift in the god they previously worshipped. People may find moral comfort in this. But just like changing your god and Bible cannot change your skin color, it cannot change people’s occupation, skills, inheritance, networks, or health, which is determined in India by caste.

The History of Schedule Caste Reservation in India

“Every culture provides at least reasonably well for those at the top of its social order. The crucial test is how it treats those at the bottom”- Wallace Mendelson

India is the only democracy in the world that made explicit constitutional provisions for compensatory discrimination, popularly known as reservations, for the advancement of historically marginalized and socially backward segments of society. Striking a balance between the necessity of compensatory discrimination in favor of specific castes and communities and its dedication to a broad definition of equality in terms of fundamental freedoms has been its primary goal. The reservation to Schedule Caste began when The Government of India 1935 Act established the SC category, granting reservations in public jobs to members of specific oppressed communities who had suffered from untouchability.  The Scheduled Castes were granted reservations under the Constitution, and Article 341 gave the President of India the authority to announce, include, or exclude the caste under the scheduled castes.

Using the power under Art 341 the first President of India, Babu Rajendra Prasad, issued the Presidential Order in 1950 as an exercise of the authority granted by the Constitution. It is evident from reading the text of Article 341 that the President’s authority is limited to defining the caste, not the religion. However, the Order makes this clear by declaring in Paragraph 3 that the SC status could not be awarded to anyone outside the Hindu community. The Order was amended in 1956 to include Dalits who had fully converted to Sikhism and again in 1990 to accept Dalits who had fully converted to Buddhism.

Point of Contention in the Presidential Order  

There exists a difference between the divine view and lived realities

The Constitution (Scheduled Caste) Order 1950 paragraph 3, issued by the president, provided reservation benefits to members of Hindu, Sikh,and Buddhist religions by recognizing them as Schedule Caste. While the amendment in 1956 & 1990 showcased the inherent Indian governance trend of clubbing Sikh and Buddhist religions under the umbrella of Hinduism, it failed to include within its ambit Islam and Christianity. This exclusion is based on the assumption that by converting to these religions, the Dalits automatically become a part of upper society, and hence, they do not require reservation. This assumption is evident from the argument given by the Government of India during the proceedings of the Centre for Public Interest Litigation and Anr. Vs Union of India.

However, the reality is that Dalit Christians or Muslims have to face almost equal oppression and marginalization even after conversion.  This different treatment is provided to them solely based on religion. Hence, this clause is seen as discriminatory based on religion and, therefore, in violation of the equality principles of Articles 14, 15, and 16 of the Indian Constitution, and has been the point of contention for several years surrounding reservations for non-Hindu Dalits in India.

Examining the Legal Battles

This issue has been in controversy for a long time, and several petitions are pending in the Supreme Court urging to provide reservations to Dalit converts to Christianity and Islam. In November 2005, the Supreme Court heard the Dalit Christian reservation case. The Union Government was asked to provide a view on the issue of granting Scheduled Caste statutory benefits and beneficiaries to those who converted to Christianity.
Consequently, the National Commission for Religious and Linguistic Minorities, or Misra Commission, was established by the UPA Government to look into the economic, social, and educational circumstances of Scheduled Caste converts to Christianity. Justice Raganath Misra served as the commission’s head. This report in 2007 recommended the Scheduled Caste reservation for Dalit converts to Christianity and Islam. Recently, rejecting the Mishra report, The government has established a new Commission in 2022 led by a former Chief Justice of India, K.G. Balakrishnan, giving it two years to make a report on the issue of conferring SC status to Dalit Converts.

Though this issue has always been controversial, it recently came into the limelight when The Tamil Nadu Assembly in 2023 passed a resolution pleading with the central government to grant all Scheduled Caste members who have converted to Christianity access to all social justice benefits, including reservation. The petitions for addressing the issue of reservation for Dalit Christians and Muslims remain unsolved, with the matter still pending before the Supreme Court. This ongoing battle continues to deprive these communities of the rights and protections extended to other Dalits.

Challenge on the Constitutionality of the Presidential Order

This classification done by the Presidential Order of 1950 creates a problem as, firstly, it establishes that religion is the sole criterion for determining socio-economic backwardness by asserting that Schedule Caste could not be extended to anyone outside the Hindu community. Secondly, it snatches from the Dalit converts(Muslim and Christian) access to beneficial legislation such as the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities Act) 1989, which is critical to preventing crimes and atrocities. To more deeply understand how this difference created by the presidential order has affected and will continue to affect the lives of Dalit converts it is critical to examine the inherent flaw in such classification:

• VIOLATIVE OF ARTICLE 14: This article lists the fundamental right of equality and equal protection of laws. It was laid down in Chiranjit Lal Sahu v Union of India that under Article 14 there can be fair distinctions made between certain groups of people. In order to demonstrate the existence of a valid classification among separate categories, two test criteria must be met. First and foremost, there needs to be discernible distinction between the classes. Second, there needs to be a logical connection between the classification and the goal it is intended to accomplish. In the case of Dalit converts classification between Hindu and Non-Hindu converts, the rationale given that Hindu scriptures, such as the Vedas, acknowledge the division of people into four varnas. Since Buddhism and Sikhism were branches of Hinduism, they were also accorded SC status. Religions such as Islam and Christianity, on the other hand, affirm an egalitarian society in which there is no hierarchy among people. However, such a connection defies logic when it comes to the state’s goal, which is full equality. It gives the texts of religious literature more respect than the harsh realities of real-life experiences.

It is important to note that although Buddhism and Sikhism defy the caste system, they still have been included under the Presidential Order. As highlighted above people who are grouped need to have shared traits that both define them as part of the group and justify their membership. When considered in this light, the inclusion of Sikhs and Buddhists in the amended Order, despite their status as “egalitarian religions” no longer makes the exclusion of Muslims and Christians a reasonable classification. Hence, the constitutionality of the provision must be assessed in light of the statute’s evolving interpretation over time.

The 2007 Ranganath Report which supported reservation to Muslim and Christian Dalit converts also supported the fact that this classification violates Article 14. Additionally, the ‘New Equality Concept’ test, which eliminated the reasonable categorization criteria in E.P. Royappa v. State of Tamil Nadu, is not met by the Presidential Order. This judgement stated that

“Equality cannot be ‘cribbled, cabined, and restricted’ within traditional and doctrinaire limitations since it is a dynamic notion. Arbitrariness is inimical to equality. Arbitrariness and equality are sworn adversaries; the former belongs to an absolute monarch’s whim, the latter to the rule of law in a republic”.

Unlike Christianity and Islam, the fundamental principles of Sikhism and Buddhism do not acknowledge the caste system. However, Muslims and Christians have been marginalized, while Sikhs and Buddhists have been discriminated against by the President’s Order, which is unjust.

• VIOLATIVE OF ARTICLE 15 – Article 15 Of the Constitution of India prohibits discrimination on grounds of religion, race, caste, sex or place of birth. The Presidential Order of 1950 violates it because it ignores the disproportionate effects it has on people who are similarly situated but excluded by religion. It is not a religion-neutral term, as the inclusion and exclusion of SCs are based on religion, which is a blatant violation of Article 15 of the Indian Constitution.

Most importantly, Muslims, Sikhs, Christians, Buddhists, Jain, and Zoroastrians (Parsis) have been notified as minority communities under Section 2 (c) of the National Commission for Minorities Act, 1992. Therefore, Sikhs and Buddhists, like Muslims and Christians, are entitled to the privileges enjoyed by minorities, including the ability to create and run educational institutions and reserve seats within them. Additionally, they are eligible for OBC, ST, and EWS reservations (which are for upper caste Sikhs and Buddhists).

Here the question emerges that why can’t Muslim and Christian minorities use the same reasoning if Sikhs (and Buddhists) are granted minority rights as a religious community and quota benefits due to their caste location? Why should Dalit-born Muslims and Christians be left out of the SC category?

With only the Dalit-originating Muslims and Christians being denied the SC status, Muslim groups such as Gadheris, gorkuns, meters or halalkhors, dhobis, backhoe, nats, primaries, lalbegis, and other Muslim communities remain destitute and oppressed as a result. It is unfair to them that they have been added to the OBC list alongside other advanced middle castes, which has had little to no effect on their lives. This inclusion highlights the recognition of caste identities within these religions, raising questions about the rationale for excluding them from the SC category. The inclusion of this religion in the OBC category highlights that these religions acknowledge caste identities. This inclusion begs the question of why they are left out of the SC group if they, in fact, acknowledge caste classification.

• VIOLATIVE OF ARTICLE 25:  This article guarantees the right to religious freedom. The view that the government supports for this classification is that it will stop wrongful conversion. This view can be ascertained from the statement of the then Union social justice minister Thavar Chand Gehlot in 2014 that

“Allowing SC status to converts would provide a fillip to religious conversions. The demand is not constitutional, and we want to work within the parameters of the statute for the welfare of these communities”

The presidential order violates this fundamental right because, under it, the Dalits would lose their SC classification if they converted to Islam or Christianity, as a consequence, the 1950 Order forbids them from following their conscience. The Order effectively keeps them as hostages because of fear of losing reservations. Due to this, the most fundamental freedoms to exercise, such as the freedom of conscience and the right to practice any religion, come at a high cost in the form of diminished protection and lost benefits.
Insidiously, paragraph 3 of the 1950 Presidential Order functions such that Dalits are penalized for selecting a religion or foregoing a religious tradition.

• VIOLATIVE OF ARTICLE 17 – This article abolishes the practice of untouchability. The presidential order works toward propagating untouchability rather than curbing it. The daily lives of DMs are dominated by untouchability practices. Practices of tight separation control norms related to food, social interactions, and access to places of worship, much like Hinduism’s caste system does. In addition to being forced to sit apart from other Muslims, they are forced to use distinct graveyards. In addition, they live apart from non-Dalit Muslims.[ii] This order of excluding them has made their situation bleaker and has left them more vulnerable to practices of untouchability.

Additionally, according to Article 13 of the Indian Constitution, any law that is inconsistent with fundamental rights is void. Since the law also includes an ‘order’ under Article 13(3)(a), this order should also be declared void for infringing the fundamental rights.

Analyzing the Case that Held the Sub-Classification of Creamy Layer as Constitutional, to Reinforce the Argument for Dalit Converts Reservation

Recently, in the case of State Of Punjab And Ors. v Davinder Singh And OrsHon’ble Supreme Court supported the view that the classification of schedule caste should not only be based on religion but on the socio-economic realities of a person by saying that the creamy layer must be excluded from schedule caste/schedule tribes for reservation. Justice Gavai stated that “Putting the children of the parents from the Scheduled Castes and Scheduled Tribes who on account of benefit of the reservation have reached a high position and ceased to be socially, economically and educationally backward and the children of parents doing manual work in the villages in the same category would defeat the constitutional mandate.” To support his view he cited the case of Jarnail Singh v. Lacchmi Narain Gupta, in which it was observed by Justice RF Nariman that “the whole object of reservation is to see that backward classes of citizens move forward so that they may march hand in hand with other citizens of India on an equal basis. This will not be possible if only the creamy layer within that class bags all the coveted jobs in the public sector and perpetuates themselves, leaving the rest of the class as backward as they always were. This being the case, it is clear that when a Court applies the creamy layer principle to Scheduled Castes and Scheduled Tribes, it does not in any manner tinker with the Presidential List under Articles 341 or 342 of the Constitution of India”

Analyzing this judgment, it is clear that the apex court of India considers the socio-economic backwardness of a person as the most important criterion for providing reservation. It states that it is unfortunate that a child whose parents have reached a high position due to the benefit of reservation gets many more resources and opportunities in addition to reservation than a child whose parents are not capable of providing him with many facilities. It reaffirms the judiciary’s commitment to ensuring that reservations reach those who are genuinely socio-economically disadvantaged.

This judgment has important implications for the ongoing debate over excluding Dalit Converts from the reservation. Applying these views to our case in point, i.e., the exclusion of Dalit converts (Christians and Muslims) from reservations, the same argument of socio-economic backwardness must be used. Dalit Christians face equal and sometimes even more oppression and marginalization than Hindu Dalits. Even after conversion, they are ‘Dalit’ first and then ‘Christian’ or ‘Muslim’, hence the name ‘Dalit Converts’. According to a study, Dalit Christians are typically located near the villages’ periphery, with other Dalit communities. Most of them reside in one-room, tiny huts constructed of wood, stone, and mud. They lack kitchens, bathrooms, and even access to clean drinking water. Compared to the national average, their sex ratio is lower. Of them, 75% have no literacy at all. Out of all women, 87% are completely illiterate. Their children even have to face caste prejudice in schools.[iii]

The Supreme Court’s emphasis on socio-economic status as the basis for reservation calls into question this exclusionary policy. If the rationale for SC reservations is indeed to uplift the socio-economically disadvantaged, it seems inconsistent to deny these benefits to individuals simply because they have converted to a different religion.

Therefore, this recent judgment should prompt a re-evaluation of the exclusion of Dalit converts from the Schedule Caste reservation framework. The commission formed under former Chief Justice of India K G Balakrishnan, appointed in 2022 by the central government to examine the matter of Scheduled Caste reservation to Dalit Converts, should evaluate this judgment and extend the principle of socio-economic equality to the issue of Dalit converts.

International Conventions and Recommendations

India is a signatory to several international conventions that guarantee different facets of the freedom of religious belief (FoRB) namely the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social, and Cultural Rights (ICESCR), the Convention on the Rights of the Child (CRC), the Convention on the Elimination of All Forms of Racial Discrimination (CERD), and the Convention on the Prevention and Punishment of the Crime of Genocide that underscore its commitment to upholding the principles of equality, non-discrimination, and social justice.

In addition to these conventions, India has also been recommended by the UN for its Freedom of Religious Belief:

• In her report, Asma Jahangir, Special Rapporteur on Freedom of Religion (Belief) in her HUMAN RIGHTS COUNCIL, recommends repealing the Presidential Order (1950) to make Affirmative Action Religion-neutral. She stated that “the legal link between Scheduled Caste status and affiliation to specific religions seems problematic in terms of human rights standards. India should recall it to restore the eligibility for affirmative action benefits for all members of Scheduled Castes and Scheduled Tribes having converted to another religion. The Special Rapporteur recommends that the Scheduled Caste status be delinked from the individual’s religious affiliation’.
• Negative Impact of Laws on Religious Conversion: Special Rapporteur, Mission to India Report states it is deeply concerned that laws and bills on religious conversion in several Indian states are being used to vilify Christians and Muslims; prohibition of conversion by a State necessarily enters into conflict with applicable international standards. Laws and bills on religious conversion in several Indian states should be reconsidered since they raise serious human rights concerns due to the use of discriminatory provisions and vague or overbroad terminology’.

By denying Dalit Christians and Muslims access to reservations, India is arguably failing to comply with its international obligations. The continued exclusion undermines the core principles of the treaties India has ratified, which advocate for the eradication of discrimination in all its forms. Providing reservations to Dalit Christians and Muslims would not only align with India’s constitutional values of equality and social justice but also reflect its commitment to upholding international human rights standards. It would send a powerful message that India is serious about addressing the systemic inequalities faced by all marginalized communities, regardless of their religious affiliations.

Way Forward

‘Whatever is wrongly settled is never settled and must be resettled’

– B.R Ambedkar

These are the ideal words to sum up the current situation. The extension of SC reservation privileges to Dalit Muslims and Dalit Christians was not brought up for discussion by Muslim or Christian members during the Constituent Assembly Debates, and this led to the unfair Presidential Order’s promulgation. The need of the hour is to implement the observation of the National Commission to Review the Working of the Constitution of 2002, which states that “completely de-link the Scheduled Caste status from religion and make the Scheduled Castes net fully religion-neutral like that of the Scheduled Tribes.” Given the considerations above, all Scheduled Castes, including those of Muslims, Christians, Sikhs, Buddhists, and Hindus, should be eligible for reservation benefits. It’s because their social standing doesn’t change even when they convert. It is, therefore, essential that they receive reservation advantages. In addition to declaring the Presidential Order, of 1950 as unconstitutional, the other measures that could be performed to curb the marginalization of Dalit converts to Christianity and Islam are:

Firstly, the government must ensure the protection of minority rights by repealing state-enacted anti-conversion laws, which have often been used to harass and marginalize religious minorities. Further, the enactment of new anti-conversion laws should be prohibited to uphold the constitutional right to freedom of religion. Secondly, it is crucial to extend legal protections and benefits under existing laws, such as the Protection of Civil Rights Act, 1955, the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (amended in 2015), and the Forest Rights Act, 2006, to Dalit Christians and Muslims. These legal provisions, originally designed to protect and uplift marginalized communities, should equally apply to Dalit converts, ensuring they receive the same level of protection and access to affirmative action benefits.

 The enactment of the Prevention of Communal and Targeted Violence (Access to Justice and Reparations) Bill, 2013, should be prioritized. This bill is vital in addressing the specific vulnerabilities faced by religious minorities, offering a legal framework for justice and reparations in cases of communal violence. It was introduced to protect religious and linguistic minorities in any state in India, as well as the scheduled castes and scheduled tribes, from targeted violence, including organized and communal violence

 By implementing these measures, the government can take significant steps towards eradicating discrimination against Dalit converts, fostering a more inclusive and equitable society. Furthermore, to identify and stop the oppression of these converts there is a need for more robust and disaggregated data on the socio-economic status of Dalit converts. This data could inform policy decisions and ensure that affirmative action benefits are extended to all marginalized groups, regardless of their religion. It would be necessary for legislative and political philosophies to alter in order to put these reforms into effect. To reflect the reality of caste-based discrimination in all societies, the existing approach that links caste identity to certain religions needs to be reevaluated. Hence, rigorous data collecting, legal reform, and persistent campaigning are necessary to overcome the discrimination Dalit converts to Islam and Christianity suffer.

Conclusion

The research paper critically examines the discrimination embedded within India’s reservation policy, particularly against Dalit converts to Christianity and Islam. Despite converting to religions that promise equality, these individuals continue to face deep-rooted societal discrimination yet are denied the constitutional protections and benefits granted to other Scheduled Castes. Based on the 1950 Presidential Order, this exclusion is a stark violation of fundamental rights guaranteed by the Indian Constitution, including the right to equality, non-discrimination, and religious freedom. The analysis highlights that socio-economic backwardness, rather than religious affiliation, should be the basis for extending reservation benefits. The Supreme Court’s stance in recent judgments supports this view, emphasizing that reservations should target those genuinely disadvantaged, irrespective of their religion. Furthermore, the paper underscores India’s failure to adhere to its international commitments to uphold equality and human rights, as the current reservation policy perpetuates systemic inequalities for Dalit converts. In conclusion, the paper calls for an urgent re-evaluation of the reservation policy to include Dalit converts to Christianity and Islam, making it truly religion-neutral. It argues that by extending these benefits, India would not only rectify a long-standing injustice but also align its policies with constitutional values and international human rights standards

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[i] P. Surya Prakash, ‘Christianity in India: A Promised Land for Dalits?’(2010) Evangelische Akademie Bad Boll < https://www.ev-akademie-boll.de/fileadmin/res/otg/641010-Prakash> accessed 3 September 2024

[ii] Prashant K. Trivedi and others, ‘Does Untouchability Exist among Muslims?’(2016) 51(15) EPW< https://www.epw.in/journal/2016/15/insight/does-untouchability-exist-among-muslims.html> accessed 3 September 2024

[iii] Godwin Shiri, Dalit Christians: A Saga of faith and Pathos, National Council of Churches in India, Nagpur, 2012. p.1.