YASHWANT S/O MANOHAR GHODMARE v. THE VICE-CHAIRMAN/ MEMBER SECRETARY, S.T. CASTE CERTIFICATE SCRUTINY COMMITTEE, NAGPUR
Quashing of Caste Invalidation Where Scrutiny Committee Arbitrarily Multiplied Contra Entries and Ignored Pre-Independence 'Mana' Tribe Records; Deterrent Costs Imposed for Perverse Findings.
Court: Bombay High Court
Citation: 2026:BHC-NAG:3391-DB
Decision Date: 25-02-2026
List of Laws
The Constitution of India, Article 226; Maharashtra Scheduled Castes, Scheduled Tribes, De-notified Tribes (Vimukta Jatis), Nomadic Tribes, Other Backward Classes and Special Backward Category (Regulation of Issuance and Verification of) Caste Certificates Act, 2000; Administrative Law - Principles of Natural Justice and Arbitrariness; Evidence Law - Probative Value of Pre-Independence Documents
- Facts: The petitioner, Yashwant Manohar Ghodmare, applied for a caste validity certificate claiming to belong to the ‘Mana’ Scheduled Tribe. His claim was initially rejected by the Scheduled Tribe Caste Certificate Scrutiny Committee, Nagpur, in 2018. Upon a successful challenge in the High Court, the matter was remanded for fresh consideration. Following the remand, a second Police Vigilance Report was conducted. Despite the petitioner submitting historical documents from 1892 to 1896 recording the caste as ‘Mana’ and citing a validity certificate granted to his real brother, the Scrutiny Committee again invalidated his claim on July 19, 2023. The Committee’s rejection was primarily based on alleged 'contra entries'—documents where the caste of relatives was purportedly recorded as ‘Kunbi’, ‘Kunbi Mana’, or ‘Mani Kunbi Hindu’.
- Procedural Posture: This is a Writ Petition filed under Article 226 of the Constitution of India challenging the order of the Scrutiny Committee dated July 19, 2023. This is the second time the petitioner has approached the High Court regarding the same claim.
- Issue: Whether the Scrutiny Committee was justified in invalidating the petitioner's ‘Mana’ Scheduled Tribe claim by relying on alleged contra entries and multiplying single records to create a false impression of inconsistent evidence?
- Holding: No, the High Court quashed the Committee's order, declared the petitioner as belonging to the ‘Mana’ Scheduled Tribe, and directed the issuance of a validity certificate.
- Reasoning: The Court found that the Scrutiny Committee’s findings were perverse and contrary to the evidence on record. Specifically, the Court observed that the Committee had deliberately "multiplied" entries of the same individual (the petitioner's cousin great-grandfather) across different school standards to falsely increase the number of contra entries. In several instances, the Committee recorded entries as 'Kunbi' even when the actual documents showed 'Mana'. Furthermore, the Committee failed to consider the validity certificate of the petitioner’s real brother and placed reliance on documents of individuals whose relationship to the petitioner was expressly denied and unproven. The Court deprecated the Committee's "pre-determined mind" to reject genuine claims and imposed a cost of Rs. 25,000/- on the Committee to act as a deterrent against such arbitrary practices.
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