IN THE HIGH COURT OF JUDICATURE AT PATNA Civil Writ Jurisdiction Case No. 9935 of 2025 ======================================================

Bharat Kumar Sharma, Son of Sh. Dineshwar Prasad Vishwakarma, resident of near Arya Samaj Mandir, Purani Chowk, Post Office Haweli Kharagpur, P.S. Haweli Kharagpur District Munger, Bihar, PIN 811213 working as Member Secretary, Central Pollution Control Board at Parivesh Bhawan, CBD-Cum-Office Complex, East Arjun Nagar, Shahdara, Delhi-32 ... ... Petitioner/s Versus

1. The State of Bihar through The Chief Secretary, Patna, Bihar.

2. The General Administration Department, Government of Bihar, Patna through its Additional Chief Secretary.

3. The Under Secretary, General Administration Department, Government of Bihar, Patna, Bihar.

4. Central Pollution Control Board, through The Chairman, Parivesh Bhawan, CBD-cum-Office Complex, East Arjun Nagar, Shahdara, Delhi-32 ... ... Respondent/s ======================================================

Appearance :

For the Petitioner/s : Mr. Satyabir Bharti, Sr. Advocate Ms. Kanupriya, Advocate Mr. Abhishek Anand, Advocate Ms. Aastha Prakash, Advocate For the Intervener : Mr. P.N. Shahi, Sr. Advocate Mr. Akash Raj, Advocate Ms. Nikita Mittal, Advocate For the State : Dr. Raisul Haque, SC-10 For the Respondent No. 4: Ms. Binita Singh, Advocate ======================================================

CORAM: HONOURABLE MR. JUSTICE BIBEK CHAUDHURI

CAV ORDER

5 17-02-2026 I. A. No. 4 of 2025

1. The present Interlocutory Application is filed by one Ms. Priya Das, praying that she be impleaded as an intervener in the present writ petition. The factual aspects of the application, as averred by the applicant, are as follows: The applicant describes herself as a public-spirited individual and social worker, serving as the Patron of the Tribal Social Welfare Trust, a registered public charitable organization focused on the upliftment and protection of the rights of Scheduled Tribes across India. She claims to have initiated multiple complaints and representations regarding the petitioner’s alleged fraudulent use of a Scheduled Tribe (ST) caste certificate to secure employment and subsequent benefits in the Central Pollution Control Board (CPCB), including his initial appointment as Assistant Environmental Engineer in 1997 and his later role as Member Secretary in 2023. These complaints were lodged with bodies such as the National Commission for Scheduled Tribes (NCST), Central Vigilance Commission (CVC), Prime Minister's Office (PMO), and the General Administration Department (GAD), Bihar, between 2023 and 2025, allegedly leading to the caste verification proceedings challenged in the main writ petition. The applicant asserts that the petitioner’s caste certificate, declaring him as belonging to the “Lohar” caste under ST, was provisional and invalidated by Bihar Government Circular No. 43 dated 23.03.1996, following the Supreme Court’s judgment in Nityanand Sharma v. State of Bihar, (1996) 3 SCC 576, yet he continued to avail benefits. She highlights her role in pursuing these complaints, including appearances before NCST and representations to the Ministry of Environment, Forest and Climate Change (MoEFCC), and argues that her intervention is necessary in public interest to safeguard ST rights from misuse. Additionally, she raises concerns about a conflict of interest due to the petitioner’s position as Member Secretary of CPCB (arrayed as a respondent) and the writ petitioner, invoking the principle of nemo judex in causa sua, and seeks to ensure impartiality in the proceedings.

2. Based on the factual aspects averred in the application and the prevailing law, the applicant cannot be impleaded as a party for the following reasons:

The dispute, as emerges from the applicant’s own averments, is confined to the verification of an individual’s personal caste certificate in the context of his employment with a Central Government organization. This is quintessentially a private di