CHETAN METHRANA SHINDE v. STATE OF MAHARASHTRA THR ITS SECRETARY TRIBAL DEVELOPMENT AND ANR
Caste Certificate Validity: Absence of Pre-Constitutional Documents Not Sole Ground for Invalidation; Scrutiny Committee Must Consider All Evidence.
Court: Bombay High Court
Citation: 2026:BHC-AS:2429-DB
Decision Date: 16-01-2026
List of Laws
Constitution of India; Scheduled Tribes; Caste Certificate Scrutiny Committee Procedures
- Facts: The Petitioner claimed to belong to the 'Phase-Pardhi, Scheduled Tribe'. The Scheduled Tribe Certificate Scrutiny Committee invalidated this claim, citing the Petitioner's failure to produce pre-constitutional documents and questioning the validity of a cousin's certificate due to lack of revenue records establishing their relationship.
- Procedural Posture: The Petitioner challenged the Committee's decision by filing a Writ Petition in the High Court of Judicature at Bombay.
- Issue: Can the Scheduled Tribe Certificate Scrutiny Committee invalidate a caste claim solely on the grounds that the petitioner failed to produce pre-constitutional documents and discarded a cousin's validity certificate due to the absence of revenue records establishing the familial relationship?
- Holding: No, the Committee cannot invalidate the caste claim solely on these grounds. The High Court allowed the Writ Petition, quashed the impugned order, and remitted the matter back to the Committee for fresh consideration.
- Reasoning: The Court held that while pre-constitutional documents have higher probative value, the absence of such documents alone cannot be a reason to invalidate a caste claim. The Committee is expected to decide the claim based on all documents produced and their probative value. The Court also noted that the Committee should have independently assessed the affidavit filed by the cousin's father instead of merely discarding the cousin's validity certificate due to the lack of revenue records. The court stated that "merely because revenue records are not produced, cannot be a ground to discard the validity certificate". The matter was remitted for fresh consideration on its own merits and in accordance with the law.
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