Shri Dhondi Suresh Palve v. State of Maharashtra

2. We have perused the order dated 12th December 2025 passed by the Hon’ble Supreme Court.

3. Brief background of the matter is as follows: The rejection of the caste claim of the Petitioner by the Caste Scrutiny Committee was challenged by the Petitioner by filing a Writ Petition before this Court, which came to be dismissed. Aggrieved by the said order, the Petitioner preferred an Appeal before the Hon’ble Supreme Court. Vide order dated 12th December 2025, the Hon’ble Supreme Court partly allowed the Appeal, set aside the order passed by this Court, and remanded the matter for fresh consideration. The relevant paragraphs from the order dated 12th December 2025 are reproduced hereinbelow for ready reference:-

4. It may be seen from the above that this Court has categorically ruled that only when the Scrutiny Committee after holding an inquiry is not satisfied with the material produced by applicant/claimant (like the appellants), the case can be referred to the Vigilance Cell. For doing so, the Scrutiny Committee is obligated to record brief reasons in support of the conclusion that it was not satisfied with the material produced by the applicant. The occasion for holding a further fact-finding inquiry by the Vigilance Cell, would arise only when preliminary test prescribed for the Screening Committee has been met with.

5. In light of the cited decision, we are satisfied that all these cases require a fresh consideration at the hands of the High Court, especially to determine whether the procedure adopted by the Scrutiny Committee, the consequential further inquiry, if any, by the Vigilance Cell, and the final conclusion arrived by the Scrutiny Committee are in consonance with the parameters laid down by this Court. These appeals are, accordingly, partly allowed, the judgment and orders of the High Court are set aside, and the cases are remanded to the High Court. The Writ Petitions filed by the appellants/claimants shall stand revived for being heard and decided afresh.

6. It is clarified that the questions of law, which are not answered by the above-cited judgment, as well as other subsequent decisions of this Court, are kept open, and the parties will be at liberty to raise all their contentions before the High Court. It also goes without saying that in this renewed consideration, the parties may rely upon additional documents, if any, and the High Court may accord them an opportunity for the same.”

4. The learned AGP opposed the petition and argued in support of the impugned order.

5. The Petitioner has filed additional affidavit dated 13th January 2026 which is taken on record and marked as ‘X’ for identification. In the said additional affidavit it is stated that during the pendency of the SLP. Respondent No.2 – Committee issued caste validity certificate to his real brother Soma Suresh Palve. The certificate of validity dated 19th December 2018 is enclosed along with the affidavit.

6. Let us examine this development in the light of the well settled legal principles governing grant of caste validity certificates to close blood relatives and its impact on the caste claim. In Maharashtra Adiwasi Jamat Saurakshan Samiti v/s. State of Maharashtra[1] the following three essential prerequisites for granting caste validity certificates were outlined by Their Lordships at the paragraph 24 of the judgment quoted above:

(i) The applicant must establish a clear and specific relationship with the person in whose favour the validity certificate has been issued;

(ii) The Scrutiny Committee must verify whether the validity certificate was granted to the applicant’s blood relative after due enquiry and in accordance with prescribed procedure; and

(iii) The Scrutiny Committee must ascertain the genuineness of the validity certificate relied upon.