In a significant judgment, the Chhattisgarh High Court underscored the quasi-judicial nature of caste scrutiny committees, emphasizing their obligation to follow principles of natural justice and statutory procedures. The ruling came in the case of Laxmi Narayan Mahto v. State of Chhattisgarh & Others (WPC No. 884 of 2015), where the court quashed the cancellation of the petitioner’s Scheduled Tribe (ST) certificate due to procedural lapses by the High Power Caste Scrutiny Committee.
Case Background
The petitioner, Laxmi Narayan Mahto, a resident of Raipur and an employee of the Postal Department since 1983, had been issued a caste certificate in 1982 identifying him as belonging to the Dhangarh community, classified as an ST in Chhattisgarh. Over the years, questions arose regarding the authenticity of this certificate, culminating in an inquiry initiated by the Senior Superintendent of Post, Raipur Division, in 2012.
The matter was referred to the High Power Caste Scrutiny Committee, which, based on a Vigilance Cell report, concluded that Mahto’s caste was Gadariya (classified under Other Backward Classes or OBC). The committee subsequently canceled his ST certificate in 2015, prompting the petitioner to challenge the decision in the High Court.
Key Legal Issues
- Adherence to the Chhattisgarh Scheduled Castes, Scheduled Tribes, and Other Backward Classes (Regulation of Social Status Certification) Act, 2013 and Rules, 2013:
The court examined whether the committee followed the procedure outlined in the 2013 Act and its Rules, including giving the petitioner adequate opportunity to present evidence and cross-examine witnesses. - Compliance with Principles of Natural Justice:
The petitioner contended that the committee failed to provide an effective opportunity for defense and relied solely on the Vigilance Cell’s report without independent verification. - Jurisdictional Authority:
The court analyzed whether the committee had jurisdiction to directly entertain a complaint from the employer, bypassing the district-level verification committee mandated under Section 6 of the 2013 Act.
Court’s Observations
Justice Bibhu Datta Guru highlighted several procedural flaws and violations of natural justice in the committee’s decision. Quoting precedents, the court reiterated the quasi-judicial nature of caste scrutiny committees and their obligation to act transparently and fairly.
The court remarked:
“The Caste Scrutiny Committee has to function as a quasi-judicial authority, which necessitates not only following the principles of natural justice but also disclosing each and every material collected by it to the person against whom the inquiry is being held.”
The judgment criticized the committee for relying solely on the Vigilance Cell report and denying the petitioner the opportunity to cross-examine witnesses or present counter-evidence.
Decision and Directions
The court quashed the committee’s order canceling the petitioner’s ST certificate and directed the High Power Caste Scrutiny Committee to conduct a fresh verification process in accordance with the 2013 Act and Rules. It emphasized that:
- All procedural safeguards under the law must be observed.
- The petitioner must be granted a reasonable opportunity to present evidence and cross-examine witnesses.
- Any inquiry should involve a thorough and impartial investigation, ensuring transparency and fairness.
The court set a six-month deadline for the fresh verification process and instructed all parties to cooperate fully.
Parties Involved
- Petitioner: Laxmi Narayan Mahto, represented by Advocate Chandresh Shrivastava.
- Respondents: State of Chhattisgarh (represented by Deputy Government Advocate Upasana Mehta), the High Power Caste Scrutiny Committee, and the Postal Department.
