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Yogesh Madhav Makalwad v. The State of Maharashtra

Civil Appeal · 2025 INSC 964Decided 12 Aug 2025
C.A. No.-010531-010531 - 2025 (arising out of SLP (C) No. 27410 of 2024)
Chief Justice · Justice Satish Chandra Sharma · Justice K. Vinod Chandran

Background

The appellant's family had been recorded as belonging to the "Koli Mahadev" Scheduled Tribe across multiple generations of school records dating back to 1943. After he qualified for medical college admission via NEET, the Scheduled Tribe Certificate Scrutiny Committee invalidated his and his father's caste certificates, and the Bombay High Court (Aurangabad Bench) upheld that decision, doubting the reliability of the old school records and citing his failure to pass an "affinity test" of tribal customs and traits.

Decision Breakdown

The Supreme Court held that pre-Independence documents, such as the 1943 school record listing the caste as "Koli Mahadev," carry greater evidentiary weight in caste disputes, and after physically examining the document, found no evidence of tampering. It further held that the "affinity test" (checking whether a person still exhibits a tribe's traditional customs and traits) is not a mandatory or decisive test, since migration and modernisation have naturally eroded such traits over generations, and cannot alone be used to override credible documentary evidence. The Court set aside both the Scrutiny Committee's and High Court's orders, declared the appellant belongs to the Koli Mahadev Tribe, and directed a validity certificate be issued within six weeks.

Lesson Learnt

In caste or tribe certificate disputes, old pre-Independence school and family records carry strong evidentiary weight, and a person cannot be denied a legitimate caste claim merely for being unable to demonstrate traditional customs that time and modernisation may have naturally faded.

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

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