Facts: Harshwardhan Devidas Gangurde, the petitioner, claimed to belong to the 'Mahadev Koli, Scheduled Tribe'. The Scheduled Tribe Certificate Scrutiny Committee invalidated his caste claim. The petitioner's father and brother already possessed validity certificates. The Scrutiny Committee discarded the certificates of the petitioner's relatives, alleging interpolations and changes in the documents and claiming the earlier certificates were issued without proper Vigilance Cell enquiry.
Procedural Posture: The petitioner filed a writ petition in the High Court of Judicature at Bombay challenging the Scrutiny Committee's order invalidating his caste claim.
Issue: Was the Scrutiny Committee justified in discarding the validity certificates of the petitioner's close blood relatives and invalidating the petitioner's caste claim, especially when prior certificates were issued without a Vigilance Cell enquiry? Can a Scrutiny Committee discard previously issued caste validity certificates to close relatives of an applicant, and deny a certificate based on a later vigilance enquiry?
Holding: No, the Scrutiny Committee was not justified in discarding the validity certificate of Navneet (petitioner's brother) and invalidating the petitioner's caste claim. The impugned order was quashed and set aside. The Scrutiny Committee was directed to issue a certificate of validity to the petitioner.
Reasoning: The Court found that the previous Scrutiny Committee had consciously decided not to refer Navneet's case to the Vigilance Cell and had issued the certificate after examining the documents. The Court relied on the Supreme Court's decision in Maharashtra Adiwasi Thakur Jamat Swarakshan Samiti Vs. State of Maharashtra and its own decision in Apoorva d/o Vinay Nichale Vs. Divisional Caste Certificate Scrutiny Committee No.1 and others, emphasizing that when a claim is based on a close blood relative's certificate, the Scrutiny Committee must verify the relationship and the genuineness of the prior certificate. The Court noted that the Scrutiny Committee cannot sit in appeal over the decision of a previous committee. The court also pointed out that no show cause notice was issued to Devidas or Navneet for cancellation/revocation of their validity certificates. The court stated, "Only when the Scrutiny Committee after holding an enquiry is not satisfied with the material produced by the applicant, the case can be referred to Vigilance Cell."