Scrutiny Committee cannot multiply entries of a single individual to create a false record of contra-evidence.

The petitioner, a student claiming to belong to the ‘Mana’ Scheduled Tribe, sought validation of his caste claim.

The Scrutiny Committee initially invalidated the claim in 2018, which was set aside by the High Court in 2022, remanding the matter for fresh adjudication.

Upon reconsideration, the Committee again invalidated the claim on July 19, 2023, primarily relying on alleged "contra entries" in historical land and school records (1892–1946) suggesting the petitioner's ancestors were recorded as 'Kunbi' or 'Kunbi Mana'.

The petitioner challenged this second invalidation, asserting that the Committee ignored the oldest "Mana" documents and a validity certificate granted to his real brother.

1. Whether the Scrutiny Committee’s finding of "contra entries" was based on a perverse interpretation of evidence and a deliberate multiplication of singular records.

2. Whether the petitioner is entitled to a ‘Mana’ Scheduled Tribe validity certificate based on the oldest available documents and the principle of consistency regarding paternal relatives.

The court applied the Maharashtra Scheduled Castes, Scheduled Tribes, De-notified Tribes (Vimukta Jatis), Nomadic Tribes, Other Backward Classes and Special Backward Category (Regulation of Issuance & Verification of) Caste Certificates Act, 2000.

The core legal principle dictates that the Scrutiny Committee must investigate claims within the parameters of this Act and judicial precedents, prioritizing the probative value of the oldest documents and maintaining consistency in family lineage claims.

The Court found the Scrutiny Committee's reasoning entirely perverse and pre-determined.

It observed that the Committee intentionally multiplied entries of a single individual, Shankar Zibal, across different school standards to falsely suggest a pattern of conflicting caste identities, whereas the actual records supported the "Mana" claim.

Specifically, the Committee recorded a 1892 Settlement document as "Kunbi" while the document itself clearly stated "Mana".

The Court noted that the Committee relied on unverified declarations and ignored the petitioner’s specific denial of relationship to certain "Kunbi" individuals.

The Court severely criticized the Committee for acting contrary to its statutory object by creating a "farce" to deprive a genuine applicant of his rights.

It declared that the petitioner belongs to the ‘Mana’ Scheduled Tribe and directed the Committee to issue the validity certificate within four weeks.

Due to the Committee's "highly deprecated" conduct in manipulating records, the Court imposed a cost of ₹25,000/- on the Scrutiny Committee, payable to the petitioner.