A relative’s caste validity supports a claimant only after their genealogical relationship is established.

The Petitioner obtained a certificate in 2000 claiming membership of the Thakur Scheduled Tribe.

In 2010, the Scheduled Tribe Certificate Scrutiny Committee invalidated her claim solely on the ground that she had failed the affinity test.

The High Court initially upheld that decision, but the Supreme Court set aside the High Court’s order and remanded the matter for reconsideration in light of Maharashtra Adiwasi Thakur Jamat Swarakshan Samiti v. State of Maharashtra.

On remand, the Petitioner relied on a caste validity certificate granted to Vishal Subhash Thakur, whom she claimed was a blood relative descending from their common ancestor, Laxman Thakur.

The genealogy she filed before the High Court did not include Vishal’s name, and the Committee had not verified the asserted relationship.

1. Whether the Committee’s rejection of the Petitioner’s claim solely for failure to satisfy the affinity test could stand in light of the governing Supreme Court authority.

2. Whether the Petitioner’s asserted relationship to Vishal Subhash Thakur, who had received a caste validity certificate, had been sufficiently established to support her claim.

In Maharashtra Adiwasi Thakur Jamat Swarakshan Samiti v. State of Maharashtra, 2023 SCC OnLine SC 326, the Supreme Court held that the affinity test is not a litmus test for determining a caste or tribe claim; where documentary evidence supports the claim, that evidence must be given due consideration.

The Court also referred to Apoorva d/o Vinay Nichale v. Divisional Caste Certificate Scrutiny Committee No. 1, 2010 (6) Mh.L.J. 401.

A relative’s caste validity certificate may be relevant to a claimant’s case, but the claimed relationship must first be established.

The Committee had rejected the Petitioner’s claim solely for failure to pass the affinity test, a basis that required reconsideration under the Supreme Court’s ruling that the test is not conclusive where documentary evidence is available.

However, the Petitioner’s reliance on Vishal’s certificate depended on proving their relationship.

Because Vishal was absent from the genealogy filed and the relationship had not been verified by the Committee, the High Court considered it appropriate to remit the matter for the Committee to examine the genealogy and the claim afresh.

It directed the Petitioner to appear before the Committee on 14 October 2026 and asked the Committee to endeavour to decide the claim within four months; all parties’ contentions were left open.

The petition was disposed of, and the Court did not itself grant the Petitioner a caste validity certificate.