In the United States v. Dolla (1910) and United States v. Balsara (1910), the courts ruled Asian Indians were white based on scientific evidence. But in 1923's United States v. Bhagat Singh Thind, Bhagat Thind, an Indian immigrant, was denied citizenship because Hindus were seen as ineligible for naturalization—one that held even though Thind was actually Sikh. This ruling was based on common knowledge and set legal precedent for the cases that would follow by determining that Asian Indians who were Hindus could not become naturalized citizens because Hindus were not considered white. This case uncovered that a religious identity, being Hindu, distanced Asian Indians from whiteness.

QUESTION: How did courts reconcile earlier rulings that treated Indians as white with the 1923 reversal based on religious identity?

Saher Selod, Forever Suspect_ Racialized…, loc. 93