Scrutiny Committees Cannot Disregard Validity Certificates of an Applicant’s Paternal Blood Relatives

The minor petitioner, through his father, sought a Scheduled Tribe validity certificate as belonging to the “Koli Mahadev” tribe.

After the Scrutiny Committee did not decide his application in time for his engineering admission, he filed an earlier writ petition.

By order dated 28 August 2026, the High Court dispensed with a Vigilance Cell inquiry and directed the Committee to decide the claim, taking account of validity certificates issued to the petitioner’s paternal blood relatives.

The Committee rejected the claim on 4 September 2026, including by relying on alleged inconsistencies and invalidated certificates.

The petitioner challenged that order, relying on four paternal relatives’ validity certificates and prior High Court decisions concerning members of his family.

Whether the Scrutiny Committee could disregard validity certificates granted to the petitioner’s paternal blood relatives when deciding his claim.

Whether the Committee’s stated concerns—including invalidated certificates among other relatives and its contemplation of challenging prior decisions—justified rejection of the petitioner’s claim.

In Maharashtra Adiwasi Thakur Jamat Swarakshan Samiti v. State of Maharashtra, (2023) 16 SCC 415, the Supreme Court held that where the Scrutiny Committee is satisfied that a person holding a validity certificate is the applicant’s blood relative and that a lawful inquiry preceded its issuance, the certificate must be considered; the applicant’s failure to satisfy the affinity test does not, by itself, defeat the claim.

The Court also relied on prior decisions recognising the significance of validity certificates granted to paternal blood relatives and directing issuance of certificates in the petitioner’s family cases.

The judgment identifies no statutory provision as the basis of its decision.

The Court found that four paternal blood relatives had received validity certificates pursuant to High Court orders, and that the Committee could not disregard those certificates when determining the petitioner’s claim.

The Committee’s reliance on other relatives’ invalidated claims did not answer the evidence of the petitioner’s paternal relatives’ validities; the Court also noted the petitioner’s response that entries 1–6 in the Committee’s chart were not paternal blood relatives.

Nor was the Committee’s intention to pursue a further challenge to prior decisions sufficient to set aside the effect of the certificates already issued.

The Committee’s rejection was therefore inconsistent with the governing precedent and the earlier order in the petitioner’s case.

It reserved liberty to reopen the petitioner’s case if any relied-upon validity holder’s certificate is invalidated in reopened proceedings, with corresponding consequences for the petitioner.

The petition was disposed of without an order as to costs.