Facts
The Petitioner, a 19-year-old student, sought validation of his caste claim as 'Mang' (Scheduled Caste, Sr. No. 46).
Source reference: para. 2-3He submitted historical documents including School Leaving Certificates of his great-grandfather (1932) and other relatives (1934) recording the caste as 'Mang'.
Source reference: para. 3A paternal relative, Prabhakar Sathe, already held a validity certificate.
Source reference: para. 10However, the Respondent No. 2 (Scrutiny Committee) invalidated the claim on September 27, 2023, observing that the Petitioner’s grandfather’s school record (1962) mentioned 'Christian' and neighbors/witnesses suggested the family professed Christianity.
Source reference: para. 4-5The Petitioner explained that the 'Christian' entry was a tactical move to avoid caste-based harassment in school and that no formal conversion occurred.
Source reference: para. 11Issues
1. Whether the mere entry of "Christian" in a school record or the presence of Christian religious symbols in a household is sufficient to establish conversion and disqualify a candidate from Scheduled Caste status.
Source reference: para. 11, 182. Whether the Scrutiny Committee was justified in discarding pre-constitutional documents and an existing family validity certificate based on suspected conversion without proof of baptism.
Source reference: para. 17-18Law Applied
The court applied the principle that the burden of proving conversion to another religion lies on the Scrutiny Committee/Vigilance Cell once a prima facie case of original caste is established by pre-constitutional documents.
Source reference: para. 16It relied on *Tejashree Mangilal Dambale v. Scrutiny Committee* regarding the weight of existing family validity certificates.
Source reference: para. 12*Bhanudas Hona Gajbhiv v. State of Maharashtra*, which held that nominal conversion for practical purposes without relinquishing Hindu faith or undergoing formal ceremonies does not strip one of Scheduled Caste benefits.
Source reference: para. 13The court further emphasized the necessity of proving the ceremony of 'Baptism' to establish conversion to Christianity, as seen in *Parvi Ashish Chakravarti v. State of Maharashtra* and *Suvarna v. State of Maharashtra*.
Source reference: para. 14-15Reasoning
The Court found the Committee's reasoning perverse and arbitrary.
Source reference: no citationIt noted that the Petitioner produced "pre-constitutional" documents from 1932 and 1934 consistently showing the caste as 'Mang'.
Source reference: para. 10-11The Court observed that the Committee failed to provide evidence of 'Baptism'—the essential sacrament for conversion to Christianity.
Source reference: para. 14, 18Following the precedent in *Kiranlata v. Divisional Caste Certificate Scrutiny Committee*, the Court held that wearing a cross, keeping a photograph of Jesus, or a clerical error in a single document (1962) does not override undisputed historical records.
Source reference: para. 15-16The Court distinguished the Apex Court's ruling in *C. Selvarani v. Special Secretary*, noting that unlike in that case, there was no evidence of Christian marriage rituals or baptismal certificates for the Petitioner or his ancestors.
Source reference: para. 17Holding
The Court allowed the Writ Petition and quashed the Scrutiny Committee’s order dated September 27, 2023.
It declared that the Petitioner duly established his status as belonging to the "Mang" Scheduled Caste.
Source reference: para. 19(iii)The Respondent No. 2 was directed to issue the Caste Validity Certificate to the Petitioner within two months.
Source reference: para. 19(iv)Rule was made absolute with no order as to costs.
Source reference: para. 20Original Court PDF
Stavan Wilson Sathe v. The State of Maharashtra & Anr. [2026:BHC-NAG:3387-DB]
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in