YOGESH MADHAV MAKALWAD v. THE STATE OF MAHARASHTRA
Discusses principles for evaluating caste claims, probative value of evidence, and limitations of the affinity test.
Court: Supreme Court of India
Citation: 2025 INSC 964
Decision Date: 12-08-2025
List of Laws
Caste Certificate and Tribe Claims
- Caste Certificate and Tribe Claims: The judgment discusses the validity of caste claims, particularly concerning Scheduled Tribes. It emphasizes the importance of documentary evidence, especially pre-Independence documents, which are considered to have a higher probative value. The judgment refers to the case of Anand v. Committee for Scrutiny & Verification of Tribe Claims and Others, specifically paragraph 22, which outlines the parameters for dealing with caste claims. It reiterates that the genuineness of a caste claim should be considered based on both documentary evidence and the affinity test. The judgment cautions against relying solely on the affinity test due to modernization and migration, which may alter traditional characteristics. It also references Maharashtra Adiwasi Thakur Jamat Swarakshan Samiti v. State of Maharashtra and Others, reiterating that the affinity test cannot be conclusive. The court emphasizes that the Scrutiny Committee must consider the affinity test results along with all other material on record.
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