The bench, comprising Justices JK Maheshwari and Sanjay Karol, delivered this ruling while allowing the appeal of Amravati MP Navneet Kaur Rana against the Bombay High Court's judgment annulling her caste certificate. The High Court had concluded that Rana obtained a 'Mochi' caste certificate deceitfully, despite indications that she belonged to the 'Sikh-Chamar' caste.
The apex court, however, upheld the validation of Rana's caste certificate by the Scrutiny Committee, affirming that it meticulously examined relevant documents and adhered to principles of natural justice. Highlighting the committee's authority conferred by the Maharashtra Caste Certificate Act, the Court emphasized that its findings should not be disturbed unless they are patently perverse.
Moreover, the Court chastised the High Court for exceeding its jurisdiction by scrutinizing the committee's findings and revaluating evidence without evidence of perversity. It stressed that the purpose of writ jurisdiction is not to reweigh evidence but to ensure procedural regularity.
Drawing from legal precedents, including Dayaram Vs. Sudhir Batham, the Court reiterated that scrutiny committees are administrative bodies tasked with verifying caste claims, not adjudicating authorities akin to courts or tribunals.
In conclusion, the Court rebuked the High Court's erroneous exercise of assessing evidence contrary to established legal principles. It emphasized that interference with the Scrutiny Committee's decisions is unwarranted if based on adequate material and procedural compliance. Thus, it set aside the High Court's judgment, affirming the Scrutiny Committee's validation of Rana's caste claim.
