RDOs must hear applicants and give detailed reasons before rejecting online ST community-certificate applications, Madras High Court says

The petitioner sought Scheduled Tribe community certificates for himself and his children, claiming they belong to the Hindu Kurumans community.

Their online applications were rejected, including on the grounds that the family had previously been classified as MBC and that supporting certificates had not been furnished.

The petitioner asserted that he had produced certificates of blood relatives and challenged the rejections under Article 226.

The respondent submitted that the applications could be pursued through the appeal process.

1. Whether the online applications could be rejected on the basis of the prior MBC classification without separately assessing the claim to Scheduled Tribe status.

2. Whether the applications should be reconsidered where the petitioner disputed the finding that adequate supporting documents had not been submitted, and whether reconsideration required a hearing and a reasoned order.

Under Clause 3.9(A)(4) of G.O. Ms. No. 104, dated 21 August 2023, after inquiry the authority may grant the certificate, reject a claim found not genuine, or return an application where the information is insufficient so that further proof may be provided.

These principles also apply to online applications.

A rejection must follow an opportunity of hearing and be supported by a speaking order.

Relying on C. Giriprasad v. Revenue Divisional Officer, W.P. No. 22990 of 2021, the Court held that the prior MBC classification could not itself determine the Scheduled Tribe claim; that claim had to be assessed independently.

The authority’s reliance on the MBC classification was not a sufficient basis to reject the claim, in light of C. Giriprasad.

The remaining reason—that relevant certificates had not been attached—was disputed by the petitioner, who asserted that he had produced certificates relating to blood relatives.

The Court therefore considered fresh scrutiny appropriate, allowing the petitioner to demonstrate the relationship and produce further evidence, while requiring the authority to assess the claim independently of the MBC certificate.

The petitioner was directed to appear within three weeks of receiving a web copy of the order; the respondent must provide a hearing, assess the evidence dehors the MBC certificate, and complete the process within three months of the petitioner’s appearance.

If rejecting an application, the authority must issue and upload a detailed speaking order after giving an opportunity of hearing.

The Court did not itself determine that the petitioner or his children were entitled to the certificates.