Equity and promissory estoppel are inapplicable to protect appointments secured through invalid or fraudulent caste certificates.

The petitioner was appointed as a Clerk in the respondent department on May 2, 1986, under the Scheduled Tribe (ST) category, based on a caste certificate identifying him as belonging to the 'Raikwar' community.

Following a show-cause notice and subsequent scrutiny, the High Power Committee (HPC), by an order dated January 7, 2005, declared the petitioner's caste certificate forged and invalid, asserting it was not issued by a competent authority.

Consequently, the petitioner was removed from service on December 5, 2006.

The petitioner challenged the removal and the HPC's findings, contending that 'Raikwar' is a sub-caste of 'Manjhi,' which is a recognized ST under the Presidential Order, 1950.

He further sought protection based on his long tenure of service.

1. Whether the High Level Caste Scrutiny Committee erred in concluding that the 'Raikwar' caste is not a recognized Scheduled Tribe and that the petitioner's certificate was invalid.

2. Whether the petitioner is entitled to equitable relief or the benefit of his long service despite the invalidation of his caste certificate.

The court primarily applied the principles established in Ku. Madhuri Patil v. Additional Commissioner, Tribal Development (1994) 6 SCC 241, which mandates the formation of High-Level Scrutiny Committees to verify caste claims and limits the scope of judicial review over their findings of fact.

The court also distinguished State of Maharashtra v. Milind (2001) 1 SCC 4, which held that in specific circumstances (such as medical professionals), completed education or long-practicing careers might be protected despite an invalid certificate, provided there was no fraud.

Furthermore, the court adhered to the principle that a High Court cannot exercise legislative powers to declare a particular caste as a sub-caste of a recognized tribe.

The Court observed that the HPC specifically found 'Raikwar' to be listed under Other Backward Classes (OBC), not Scheduled Tribes.

It held that it is beyond the jurisdiction of the High Court to determine whether 'Raikwar' is a sub-caste of 'Manjhi,' as such classifications are strictly governed by the Presidential Order.

In applying Madhuri Patil, the Court emphasized that findings of fact by a specialized committee must prevail unless found to be perverse or vitiated by an error of law.

The Court distinguished the Milind precedent, noting that while the Supreme Court protected a doctor due to the public interest and resources spent on medical education, such logic does not extend to the petitioner who held the post of a 'Clerk'.

Finally, the Court noted that a party seeking equity must come with clean hands; since the petitioner obtained employment on a false social status, the principles of promissory estoppel or equity cannot be invoked to rescue a claim rooted in fraud.

The Court affirmed that the subsequent orders of removal from service and the appellate order were passed in consonance with the evidence on record.

No interference with the impugned orders was warranted.