Third party lacks locus standi to challenge the validity of another individual’s caste certificate.

The petitioner, a resident of a tribal area in Dahod District, filed a petition under Article 226 of the Constitution read with the Scheduled Castes and Scheduled Tribes Orders (Amendment) Act, 1976.

The petitioner alleged that Respondent No. 7 (Bharatsinh Badarsinh Rathva) obtained a Scheduled Tribe (ST) certificate (No. 1697, dated 08-07-1994) through the submission of false information and fabricated documents, including revenue records and pedigrees.

Despite a representation dated 06-11-2025, the state authorities (Respondents 1-5) allegedly failed to initiate an inquiry.

The petitioner sought a writ of certiorari to quash the 1994 certificate and a declaration that Respondent No. 7 does not belong to a Scheduled Tribe.

1. Whether the petitioner possesses the locus standi to challenge the validity of a caste certificate issued to a third party.

2. Whether the Court should exercise its writ jurisdiction to quash a caste certificate issued by a competent authority over three decades prior, based on the petitioner's allegations of fraud.

The court primarily applied the doctrine of locus standi under Article 226 of the Constitution of India, which restricts the right to seek judicial review to those who can demonstrate a specific legal injury or a sufficient interest in the matter.

The court also acknowledged the statutory framework of the Scheduled Castes and Scheduled Tribes Orders (Amendment) Act, 1976, regarding the issuance and verification of caste status by competent administrative authorities.

The court evaluated the petitioner’s standing and the legitimacy of the administrative action. It noted that the impugned certificate was issued in 1994 after the concerned authority performed a verification of the relevant documents produced at that time.

The court reasoned that the petitioner had no legal standing (locus standi) to represent the interests involved or to lodge objections against the personal status certificate of Respondent No. 7.

Because the certificate was issued following due process by the competent authority, the court found no merit in the petitioner's claim that the inaction of the authorities was contrary to law.

The High Court dismissed the petition, ruling that it was devoid of merit. Consequently, the Rule was discharged, and no directions were issued to the respondent authorities.