Cancellation of a caste certificate was upheld following findings of non-residence and alleged submission of forged documents.

The petitioner challenged, under Article 226 of the Constitution, the order/letter dated 10 March 2025 by which his caste certificate dated 1 August 2022, bearing Registration No. RS/451/0104/61882/2022, was cancelled on the ground that it had been issued contrary to the applicable rules and on the basis of false information.

The State authorities alleged that the petitioner was not a resident of Tehsil Ranjhi and had submitted forged documents to obtain the certificate. A criminal case was also registered against him at Police Station Ranjhi, Jabalpur, for offences under Sections 420, 467, 468, 471 and 34 of the Indian Penal Code, and departmental proceedings were proposed. The petitioner contended that the cancellation followed an ex parte enquiry, that he was denied an opportunity to present evidence, and that “Manjhi” is a notified Scheduled Tribe in Madhya Pradesh.

Whether the cancellation of the petitioner’s caste certificate dated 10 March 2025 was illegal or vitiated by violation of the principles of natural justice, particularly because the enquiry was allegedly conducted ex parte.

Whether the petitioner was entitled to restoration of his caste certificate on the ground that “Manjhi” is a notified Scheduled Tribe and that having two places of residence did not justify cancellation.

Whether the High Court should quash the criminal proceedings registered for alleged use of forged documents in obtaining the caste certificate.

The Court exercised its constitutional jurisdiction under Article 226 of the Constitution to examine the legality, propriety, and validity of the impugned administrative action.

The applicable principles included the requirement that administrative decisions comply with the principles of natural justice and be free from illegality, perversity, or procedural infirmity. The Court also considered the criminal allegations under Sections 420, 467, 468, 471 and 34 of the Indian Penal Code concerning cheating, forgery, use of forged documents, and common intention. No specific judicial precedent was relied upon in the judgment.

The Court accepted the State’s position that the caste certificate had been cancelled after an enquiry which found that the petitioner was not a resident of Tehsil Ranjhi and that forged documents had allegedly been submitted for obtaining the certificate.

It further took note of the pending criminal proceedings relating to the alleged forgery. On that basis, the Court found no illegality, perversity, or infirmity in the impugned order. Although the petitioner alleged breach of natural justice and relied on the recognition of “Manjhi” as a Scheduled Tribe, the Court did not find those contentions sufficient to displace the administrative finding or justify interference under Article 226.

It declined to restore the certificate and refused to quash either the impugned order dated 10 March 2025 or the criminal proceedings arising from the alleged submission and use of forged documents. The writ petition was accordingly dismissed as devoid of merit.