Instead, he attempted to be classified as a "free white person" within the meaning of the Naturalization Act based on the fact that Indians and Europeans share common descent from Proto-Indo-Europeans.

"[4] Bhagat Singh Thind had come to the United States in 1913 for higher studies after obtaining a bachelor's degree in India.

The case then reached the Supreme Court, where Sakharam Ganesh Pandit, a California attorney and fellow immigrant, represented Thind.

[9] Sutherland found that, while Thind may claim to have "purity of Aryan blood" due to being "born in Village Taragarh Talawa near Jandiala Guru, Amritsar, Punjab", he was not Caucasian in the "common understanding", so he could not be included in the "statutory category as white persons".

"[9] Justice Sutherland wrote in his summary:[11] The eligibility of this applicant for citizenship is based on the sole fact that he is of high caste Hindu stock, born in village Taragarh Talawa, Amritsar district, Punjab, one of the extreme north western districts of India, and classified by certain scientific authorities as of the Caucasian or Aryan race ...

The rules of caste, while calculated to prevent this intermixture, seem not to have been entirely successful ... the given group cannot be properly assigned to any of the enumerated grand racial divisions.

Not only were new applicants from India denied the privilege of naturalization, but the new racial classification suggested that the retroactive revocation of United States citizenship granted to Asian Indian Americans, of which there were many, might be supported by the Court's decision, a point that some courts upheld when United States attorneys petitioned to cancel the citizenship previously granted to many Asian Indian Americans.

However, Pandit successfully argued before the Ninth Circuit that revoking his citizenship would do him and his wife unfair harm under the equitable estoppel doctrine.

[15] His citizenship was upheld, and the Bureau of Naturalization subsequently cancelled its pending denaturalization cases against Indian American citizens.

Hurdling over many members of Congress and the American Federation of Labor, which vehemently opposed removing legislative measures barricading Indian immigration and naturalization, the Asian Indian community finally succeeded in gaining support among several prominent congressmen, as well as President Franklin D. Roosevelt.

This Act reversed the Thind decision by explicitly extending racial eligibility for naturalization to natives of India, and set a token quota for their immigration at 100 per year.