Quasi-Judicial Authorities Must Issue Speaking Orders Addressing Specific Objections to Satisfy Principles of Natural Justice

This is the second round of litigation concerning the petitioner’s caste status. In the first round (WP No. 20085/2015), the High Court set aside the State Level Caste Scrutiny Committee's decision and remitted the matter for a fresh decision after affording the petitioner an opportunity of hearing.

Pursuant to that order, the Committee issued notices, and the petitioner submitted historical evidence and objections.

The Committee subsequently passed the impugned order affirming the Superintendent of Police’s (SP) report, which stated there was no record of the petitioner’s father’s caste being 'Julaha' in his ancestral village.

The petitioner challenged this order, contending it was non-speaking and failed to discuss the evidence he provided.

1. Whether the State Level Caste Scrutiny Committee acted in a quasi-judicial manner by providing a speaking order that addressed the petitioner’s specific contentions.

2. Whether the impugned order satisfied the principles of natural justice and the specific directions issued by the High Court in the previous round of litigation.

The court emphasized that a Caste Scrutiny Committee must act as a quasi-judicial authority, meaning it is legally obligated to deal with the evidence/stand of the parties and assign clear findings rather than acting in a mechanical manner.

The court referred to the procedural guidelines for caste verification established by the Supreme Court in Madhouri Patil v. Additional Commissioner.

While the respondents cited Navneet Kaur Ravi Rana v. State of Maharashtra and Yogesh Madhav Makalwad v. State of Maharashtra to argue against interference with Committee findings under Article 226, the court held these precedents were inapplicable where there is a fundamental failure to adhere to the principles of natural justice.

The Court observed that while the Committee’s order reproduced the petitioner’s stand across several pages, the actual "decision" section lacked any substantive discussion of that stand.

The Committee merely recorded a concurrence with the Superintendent of Police’s report, effectively treating the police inquiry as final without evaluating the petitioner’s rebuttal or oral evidence.

The Court reasoned that since the Committee is a quasi-judicial body, it cannot pass a "virtually non-speaking" order that ignores the specific objections raised by the aggrieved party.

Because the Committee failed to "deal with the stand of the present petitioner and assign findings," the order was deemed mechanically passed and legally unsustainable.

The matter was remitted back to the High Level Caste Scrutiny Committee with a direction to pass a fresh, speaking order addressing the petitioner's objections within 90 days of the parties' appearance.

The Court ordered the parties to appear before the Committee on 03/08/2026.

Holding that the decision was reached in violation of natural justice, the Court dismissed the State's reliance on restrictive precedents regarding judicial review.