Pre-Independence records prevail over nomenclature variations in determining Scheduled Caste status.

The petitioner, a Lecturer appointed in 1983 under the Scheduled Caste (SC) category, challenged an order dated 25.01.2020 passed by the High Power Certification Scrutiny Committee (HPC).

The HPC cancelled the petitioner’s "Mahar" caste certificate and directed penal action under Section 9(3) of the Chhattisgarh Scheduled Castes, Scheduled Tribes and Other Backward Classes (Regulation of Social Status Certification) Act, 2013.

The cancellation was based on a Vigilance Cell report which claimed the petitioner belonged to "Baya Mahara"—a non-notified category—citing variations in nomenclature in certain documents.

However, the petitioner relied on a pre-Constitution document from 1929 recording his forefather’s caste as "Mahar," and an Investigation Assistant's report affirmed his affinity with the "Mahar" community.

1. Whether the High Power Certification Scrutiny Committee’s order was legally sustainable given the existence of pre-1950 documentary evidence and a favorable affinity report?

2. Whether marginal variations in nomenclature (e.g., "Mahara" or "Baya") in subsequent records can override ancient ancestral documents for the purpose of caste determination?

The Court applied the guidelines from Ku. Madhuri Patil v. Addl. Commissioner, Tribal Development (1994), which established that ancient, pre-Constitution documents carry higher probative value in social status determination.

It relied on Anand v. Committee for Scrutiny and Verification of Tribe Claims (2011), holding that caste verification must consider the cumulative effect of documentary evidence and affinity tests rather than isolated discrepancies in nomenclature.

The Court further referenced State of Maharashtra v. Milind (2001), emphasizing that findings must rest on clear legal foundations and that long-standing benefits should not be disturbed absent proof of fraud.

The proceedings were governed by the Chhattisgarh Scheduled Castes, Scheduled Tribes and Other Backward Classes (Regulation of Social Status Certification) Act, 2013 and the Rules of 2013.

The Court observed that the petitioner produced a document from 1929 recording his paternal lineage as "Mahar," which, being a pre-Constitution record, is less susceptible to manipulation and provides a reliable basis for status.

It criticized the HPC for ignoring the Investigation Assistant’s favorable affinity report without providing cogent reasons.

The Court found the Vigilance Cell’s introduction of the term "Baya Mahara" to be unsupported by statutory notifications and characterized it as a non-existent category.

Furthermore, the Court noted that the petitioner had served for over four decades (since 1983) without any finding of fraud or deliberate misrepresentation; therefore, long-standing civil consequences cannot be disturbed on a "doubtful interpretation" of caste entries.

It concluded that marginal inconsistencies in later records cannot dislodge foundational ancestral documents.

The Court quashed and set aside the HPC’s order, thereby validating the petitioner’s status as a member of the "Mahar" Scheduled Caste.

The writ petition was allowed.