Three-Judge Bench of this Court in State of Kerala v. Chandramohan, (2004) 3 SCC 429 had an opportunity to discuss the concept of ‘tribe’ and its characteristics. It becomes clear, once a person belonging to a Scheduled Tribe converts to another religion, ultimately through passage of time, customs, rituals and other traits of that particular ‘tribe’ may fall into eclipse. In such circumstance, a reasonable inference can be drawn, such a person shall not be considered a part of the ‘tribe’.

A determination of Scheduled Tribe status cannot rest on conversion alone, but must turn on whether claimant continues to possess and is recognised for essential attributes of tribal identity, including customary practices, social organisation, community life, and acceptance by concerned tribal community. Where conversion or subsequent conduct results in a complete severance from tribal way of life and loss of community recognition, foundational basis for Scheduled Tribes status will stand eroded. Conversely, where such attributes demonstrably subsist or are genuinely re-established and accepted by tribal community, a claim cannot be rejected mechanically.

– Hon’ble Justice Prashant Kumar Mishra, Chinthada Anand v. State of Andhra Pradesh, [Criminal Appeal No. 1580 of 2026].