High Courts Should Not Ordinarily Interfere With Scrutiny Committee's Findings On Caste Claims Unless Findings Are Perverse : Supreme Court

The Supreme Court today (on April 04), in a crucial judgment pronounced by it, opined that in cases where the scrutiny committee has decided the validation of the caste claim, the Courts should refrain from interfering unless the committee's decision suffers from any perversity.

“It is well settled that High Courts as well as Supreme Court should refrain themselves from deeper probe into factual issues like an appellate body unless the inferences made by the concerned authority suffers from perversity on the face of it or are impermissible in the eyes of law.,” the judgment read.

The Bench of Justices JK Maheshwari and Sanjay Karol made these observations while allowing Amravati MP Navneet Kaur Rana's appeal against the Bombay High Court judgment, which had canceled her caste certificate. In the impugned judgment, the High Court had observed that Rana fraudulently obtained 'Mochi' caste certificate, even though records indicated that she belonged to the caste 'Sikh-Chamar'.

However,  the Top Court held that the Scrutiny Committee had validated Rana's caste certificate after due application of mind and on considering relevant documents. All documents were duly considered, and reasons were given while accepting/rejecting other certain documents. Further, all parties were heard, and the principles of natural justice complied with. Basis this, the Court was of the view that the findings of the committee should not be disturbed.

At the outset, the Court underlined the powers given to the scrutiny committee by virtue of 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 Certificate Act, 2000. This act gives the committee vast powers to conclude the certificate's genuineness. Further, the committee's order is said to be final, except that the High Court can interfere with the same under its writ jurisdiction.

“Once the Scrutiny Committee after hearing the contesting parties and evaluating the documents on record reached on conclusion based on its satisfaction and application of mind, the question that arises for consideration of this Court in the particular facts of this case is that how far the High Court was justified in completely overturning the findings of Scrutiny Committee in exercise of jurisdiction under Article 226 of the Constitution of India by reappraisal of the entire evidence on record?.,” the Court asked.

Following this, the Court, in no uncertain terms, observed that the High Court had clearly overstepped by interfering with the committee's findings and re-appreciating the evidence without there being any perversity with such an order.

Notably, the Court also recorded that the Scrutiny Committee had sole authority to assess the adequacy of evidence in the case. The High Court should not have routinely entertained challenges to this assessment.

To strengthen this, the Court also cited the precedent of Dayaram Vs. Sudhir Batham and Others., (2012) 1 SCC 333. In this precedent, the Court had clearly observed that a Scrutiny Committee is not an adjudicating authority like a Court or Tribunal rather, it is an administrative body that verifies the fact, investigates a specific caste claim, and ascertains whether the caste claim is correct, or not

It may be noted that the High Court had invoked the writ of certiorari to quash the committee's decision. However, the Top Court categorically observed that the purpose of this writ is not to review or reweigh evidence.

“The jurisdiction is supervisory and the Court exercising it, ought to refrain to act as an appellate court unless the facts so warrant. It also ought not re¬appreciate the evidence and substitute its own conclusion interfering with a finding unless perverse. The High Court in a writ for certiorari should not interfere when such challenge is on the ground of insufficiency or adequacy of material to sustain the impugned finding.,” the Court added.

Pertinently, cases, including Central Council for Research in Ayurvedic Sciences and Another vs. Bikartan Das and Others, 2023 LiveLaw (SC) 692, were cited to support this finding.

In light of the prevailing facts and circumstances, the Court concluded that the High Court “inadvertently undertook an erroneous exercise of appreciating evidence” that was not in accordance with the established position of law.

“The High Court ought not to have interfered, especially when Scrutiny Committee had followed the due procedure under Rule 12, 17 and 18 of the 2012 Rules and that there was nothing perverse about a finding of fact.,”

"If the findings of the Scrutiny Committee are based on the materials specified under Rule 16 followed by its subjective satisfaction, then exercise of jurisdiction under writ of certiorari to quash the order of validation of caste claim by Scrutiny Committee is unwarranted and uncalled for," the judgment concluded while setting aside the impugned judgment of the High Court. 

Case Details: Navneet Kaur Harbhajansingh Kundles @ Navneet Kaur Ravi Rana v. The State of Maharashtra and Ors. | Civil Appeal No. 2741-2743/2024

Citation : 2024 LiveLaw (SC) 278

Click here to read the judgment