2026 Supreme(Online)(Kar) 20638

THE HIGH COURT OF KARNATAKA
Vibhu Bakhru, CJ, C.M. Poonacha, J
G. Manjunatha – Appellant
Versus
State of Karnataka – Respondent
WRIT APPEAL NO. 435 OF 2024

The lists of scheduled castes and tribes defined by the Presidential Order under the Constitution are exhaustive. Courts and administrative authorities possess no power to modify or allow evidence to include castes not explicitly mentioned in the official list through interpretation or alleged ethnographic equivalence.

Headnote:(A) Constitution of India - Articles 341 and 342 - Presidential Orders regarding Scheduled Castes - Modification of list - Competence of Parliament - It is only Parliament that is competent to amend the Orders issued under Articles 341 and 342. No inquiry is permissible and no evidence can be let in for establishing that a particular caste or part or group within tribes or tribe is included in the Presidential Order if they are not expressly included therein. (Paras 51, 52)

(B) Karnataka Scheduled Castes, Scheduled Tribes and Other Backward Classes (Reservation of Appointment Etc.) Act, 1990 - Sections 4, 4A, 4C, 4D, 4E and 4F - Burden of proof - Burden of proving that a candidate belongs to a Scheduled Caste rests on the applicant - Verification Committees have the power of civil courts regarding evidence and document production. (Paras 30, 33, 35)

(C) Appellate practice - Delay in judgment pronouncement - Guidance provided by judicial precedents regarding delay in pronouncement do not automatically mandate setting aside an order unless there is demonstrable prejudice or specific argument omitted from consideration. (Paras 22, 24)

Facts of the case:
The appellant sought to challenge a report submitted by a caste verification committee which concluded that the appellant did not belong to the scheduled caste category. The appellant had previously relied on a caste certificate that was allegedly issued through illegitimate electronic entries. Multiple judicial forums and administrative bodies had previously found that the appellant belonged to a different caste category that falls under the backward classes rather than the scheduled caste list, based on school records and family documentation.

Findings of Court:
The court upheld the findings of the lower authority, noting that the caste previously identified in personal and public records corresponds to a backward class category. The court rejected the argument that the appellant should be deemed to belong to a scheduled caste based on alleged ethnographic similarities, affirming that such equivalence cannot be established by courts against the express declarations in the Presidential Orders.

Issues: The central issues were the validity of the caste inquiry, the evidentiary value of personal and school documents indicating a different caste identity, and whether courts can equate non-included castes with listed scheduled castes based on cultural or occupational similarities.

Ratio Decidendi: The court maintained that administrative and judicial authorities are prohibited from modifying or expanding the list of scheduled castes defined by the Presidential Order. Since the appellant failed to discharge the burden of proof required under the statute and failed to present evidence rebutting the official records showing a different caste status, the challenge to the verification committee's report was dismissed.

Result: Appeal dismissed.