Chhattisgarh High CourtAdministrative and Public LawConstitutional Law

Teacher’s Caste Certificate Cancellation Quashed As Chhattisgarh HC Finds District Panel Lacked Authority And Gave No Hearing

PRABHAT KUMAR SANGAMv.STATE OF CHHATTISGARH

Teacher’s Caste Certificate Cancellation Quashed As Chhattisgarh HC Finds District Panel Lacked Authority And Gave No Hearing. PRABHAT KUMAR SANGAM vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
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In brief

The question

1. Whether the District Level Certificate Verification Committee was competent to cancel the petitioner’s caste certificate

The court held

The Court quashed the Committee’s order/inquiry report dated 6 January 2026.

It also directed

It left the respondent authorities at liberty to refer the matter to the High Power Certification Scrutiny Committee, if warranted, subject to compliance with the applicable statutory provisions and affording the petitioner an adequate opportunity of hearing. The petition was allowed, with no order as to costs

01Facts

The petitioner challenged the District Level Certificate Verification Committee’s order/inquiry report dated 6 January 2026, which cancelled his caste certificate as forged and fabricated and recommended recovery of benefits and termination of his services.

¶ 1–3

He contended that the Committee lacked authority to cancel the certificate and had not followed the procedure prescribed by law. The State submitted that the authorities would act in accordance with law

¶ 1–3

02Issues

i.1. Whether the District Level Certificate Verification Committee was competent to cancel the petitioner’s caste certificate

¶ 2, 4

ii.2. Whether the Committee could cancel the certificate and make consequential recommendations without notice and an opportunity of hearing to the petitioner

¶ 4

03Law Applied

The Court referred to the Chhattisgarh Scheduled Castes, Scheduled Tribes and Other Backward Classes (Regulation of Social Status Certification) Act, 2013, and the Rules framed under it, observing that caste-certificate verification and cancellation must be undertaken by the authority competent under the applicable statutory provisions.

¶ 2, 4–5

It also applied the principles of natural justice: action having civil consequences must not be taken without following the prescribed procedure and providing an adequate opportunity of hearing

¶ 2, 4–5

04Reasoning

The District Level Committee cancelled the petitioner’s certificate and recommended recovery of benefits and termination without issuing notice or affording him a hearing. The Court held that these actions had civil consequences and could not be taken without procedural fairness.

¶ 4

It further found that the Committee could not assume powers conferred on the High Power Certification Scrutiny Committee where the statute did not grant it that authority

¶ 4

05Holding

The Court quashed the Committee’s order/inquiry report dated 6 January 2026.

¶ 5–6

It left the respondent authorities at liberty to refer the matter to the High Power Certification Scrutiny Committee, if warranted, subject to compliance with the applicable statutory provisions and affording the petitioner an adequate opportunity of hearing. The petition was allowed, with no order as to costs

¶ 5–6
Chhattisgarh High Court

Original Court PDF

PRABHAT KUMAR SANGAMvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 28, 2026

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