2026 Supreme(Online)(Chh) 8483

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Amitendra Kishore Prasad, J
Indrapal Bhaskar – Appellant
Versus
State of Chhattisgarh – Respondent
WPC No. 840 of 2020

Pre-independence documents carry the highest probative value in caste verification. An affinity test is not a conclusive litmus test, and in the absence of fraud or misrepresentation, the cancellation of a long-standing caste status and subsequent service termination is legally unsustainable and disproportionate.

Headnote:(A) Constitution of India - Article 341 - Scheduled Castes - Caste verification - Determination of social status - Pre-independence documents regarding ancestral lineage carry the highest probative value and should be preferred over post-independence records containing discrepancies. (Paras 9, 23, 29)

(B) Caste Scrutiny - Affinity Test - It is not a litmus test for establishing the link of an applicant with a specific caste, especially when modern migration and social contact occur. Such test should be used to corroborate documentary evidence rather than functioning as the sole criterion for rejection. (Paras 26, 28)

(C) Administrative Law - Quasi-judicial orders - Requirement of reasoning - Statutory authorities must provide cogent, reasoned orders based on all available evidence. A decision based on an artificially coined category not supported by any statutory notification or record is perverse and reflects non-application of mind. (Paras 23, 33)

(D) Service Law - Protection against ouster - In the absence of any finding of fraud, misrepresentation, or fabrication of records, the cancellation of a caste certificate and subsequent termination of long-standing service is arbitrary and disproportionate. (Paras 27, 30, 31)

Facts of the case:
The petitioner, employed as a teacher, had his caste certificate cancelled by the scrutiny committee following a complaint alleging the certificate was obtained through misrepresentation. The committee concluded the petitioner belonged to a different caste category, relying on later school records and creating a new nomenclature, while ignoring pre-independence revenue records and affinity reports that supported the petitioner's claim of being a member of a notified Scheduled Caste.

Findings of Court:
The court found that the scrutiny committee failed to properly appreciate the evidentiary value of pre-independence documents, which established the petitioner's lineage. The committee's reliance on inconsistent post-independence documents and the invention of an unsupported caste category rendered the decision perverse. Furthermore, the absence of proof of fraud made the punitive consequences of certificate cancellation and service termination disproportionate.

Issues: Whether the committee's decision to revoke the caste certificate, based on the rejection of pre-independence records in favor of inconsistent recent entries, was legally sustainable; and whether the cancellation of service sans proof of fraud was valid.

Ratio Decidendi: Pre-independence records constitute the best evidence for caste determination. When documentary evidence and social acceptance align, an affinity test cannot act as a sufficient basis for rejection. Decisions devoid of cogent reasoning and proper appreciation of evidence are non-est and liable to be set aside.

Result: Petition allowed; impugned order quashed and set aside; the caste certificate is declared valid and subsisting.