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Navneet Kaur Harbhajansing Kundles @ Navneet Kaur Ravi Rana vs. The State of Maharashtra

Not available · 2024 INSC 266Decided 4 Apr 2024
Not available
Justice J.K. Maheshwari · Justice Sanjay Karol

Background

The appellant, a sitting Member of Parliament from Amravati (Maharashtra), had won the 2019 election on a seat reserved for Scheduled Castes based on a "Mochi" caste validity certificate. Rival candidates challenged the certificate as fraudulently obtained, but Maharashtra's Caste Scrutiny Committee validated her claim in 2017, relying mainly on an old college certificate showing her grandfather's caste and a 1932 tenancy document showing her family's migration from Punjab. The Bombay High Court later quashed the Scrutiny Committee's validation, cancelled her certificate, and imposed a Rs. 2 lakh cost on her, prompting this appeal.

Decision Breakdown

The Supreme Court held that a Scrutiny Committee constituted under the Maharashtra caste-certificate law is an expert fact-finding body whose decisions are meant to be final, and a High Court exercising its writ (certiorari) jurisdiction under Article 226 cannot re-appreciate evidence or substitute its own view unless the Committee's findings were perverse or based on no evidence. The Court found the Scrutiny Committee had followed due procedure, given all parties a hearing, and reasonably relied on the two documents to accept the caste claim under the applicable law and rules: a decision the High Court had wrongly second-guessed through a "roving inquiry." The Court also rejected the argument that validating her claim would improperly amend the Presidential Order listing castes, since "Mochi" was already a recognized entry for Maharashtra. The High Court's judgment was set aside and the Scrutiny Committee's original validation was restored.

Lesson Learnt

Courts reviewing decisions of specialized fact-finding bodies like caste scrutiny committees through a writ of certiorari can only intervene for jurisdictional errors or perverse findings. They cannot reweigh the evidence themselves as if hearing a fresh appeal.

Official source (sci.gov.in)View Judgment (PDF)

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