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2026 Supreme(Online)(Guj) 5980

IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
Aniruddha P. Mayee, J
DHRUPESH HARESHBHAI CHAVDAV/sSTATE OF GUJARAT
R/SPECIAL CIVIL APPLICATION NO. 6116 of 2025 | C/SCA/6116/2025



Advocates:
For the Appellants/Petitioners: Ninad P Shah, Shalin Mehta
For the Respondents: Nikunj Kanara

An authority rejecting a caste certificate must consider all submitted evidence and issue a reasoned order providing specific findings on the genuineness and veracity of each document, adhering to the principles of natural justice.

Headnote:The petitioner challenged an order dated 31.05.2025 passed by the Mamlatdar, Ranavav, which rejected an application for the issuance of a caste certificate. It was contended that the authority selectively relied on a few documents and ignored several others, including certificates of immediate family members and a recommendation from the Scheduled Tribe Caste Certificate Committee dated 10.04.2017. The court found that the impugned order was silent on key evidence and failed to provide definite findings regarding the genuineness of the documents produced. The primary issue was whether the authority had properly considered all available evidence and provided a reasoned order for the rejection of the caste claim. The court reasoned that the authority must examine the claim by following the prescribed procedure and the principles of natural justice, ensuring that a finding is rendered on the genuineness and veracity of each document produced, supported by cogent reasons. The present writ petition is allowed to the aforesaid extent. Rule is made absolute to the aforesaid extent.

Table of Content
1. challenge against the rejection of a caste certificate application. (Para 1 , 2)
2. dispute over the adequacy of document scrutiny and availability of alternative remedies. (Para 3 , 4 , 5)
3. failure of the administrative authority to consider all submitted evidence and provide reasoned findings. (Para 6 , 7)
4. requirement for remand to ensure a reasoned adjudication based on natural justice. (Para 8 , 9 , 10)

ORAL ORDER

1. Rule . Rule returnable forthwith. Learned AGP waives service of notice of rule on behalf of the respondent-State.

2. By the present writ petition, the petitioner is impugning the order dated 31.05.2025 passed by the Mamlatdar, Ranavav by which the petitioner’s application for issuance of caste certificate is rejected.

3. Learned Senior Advocate Mr.Shalin Mehta appearing for the petitioner submits that the learned Mamlatdar has not rendered any findings on the documents so produced by the petitioner in support of his caste claim. He submits that in the present case the petitioner had produced the number of documents on record, however, the learned Mamlatdar, in the impugned order, has only relied upon a few of the documents selectively. He submits that the impugned order has been passed only on the basis of five documents. He further submits that the impugned order also does not record any finding as to the genuineness of the documents, which are relied upon by the petitioner herein.

4. Learned Senior Advocate Mr.Mehta submits that the petitioner has relied upon the caste certificates issued in favour of immediate family members as well as the cousins of the petitioners. He submits that the petitioner was also recommended for issuance of caste certificate by the Scheduled Tribe Caste Certificate Committee headed by the learned Mamlatdar vide communication dated 10.04.2017, wherein three members’ committee has concluded that the petitioner is entitled for the status of Scheduled Tribe. He submits that the Mamlatdar by the impugned order could not have taken a contrary view. He further submits that even the findings recorded on the basis of documents so relied upon by the learned Mamlatdar are inconclusive. He, therefore, submits that the impugned order is bad in law and the same be remanded back for fresh adjudication since the only reasoning granted by the learned Mamlatdar is that the documents so produced by the petitioner in support of his claim are unsatisfactory, and therefore the caste certificate has been denied to the petitioner.

5. Per contra, Mr.Ninkunj Kanara, learned AGP appearing for the respondents submits that the learned Mamlatdar has scrutinized all the documents submitted by the petitioner in support of his contentions. He submits that as per the reasons recorded by the learned Mamlatdar, the petitioner has submitted the documents of which the genuineness could not be ascertained. He submits that some of the documents could not be verified from the copies submitted by the petitioner from the official records. He, therefore, submits that the learned Mamlatdar has come to a conclusion that the evidence in support of the caste claim is not satisfactory and accordingly, he has rejected the claim of the petitioner. He further submits that if the petitioner is aggrieved by the order, he has an alternative efficacious remedy of appeal before the Additional Collector.

6. Heard the learned counsel for the parties. Considered the submissions and perused the documents on record.

7. In the present case, the petitioner has produced the caste certificates issued to his grandfather, thereafter to his father, to his mother, to his uncles and his cousins. The petitioner has also produced on record the minutes of the meeting dated 10.04.2017 of the Scheduled Tribe Caste Committee under the Chairmanship of Mamlatdar, Ranavav, wherein the petitioner has been granted the status of Scheduled Tribe. The said committee has also taken into consideration the Vigat Darshak

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