Shashikant Pandit Patil and Anr. vs the State of Maharashtra Throu. Govt Pleader and Ors. — Bombay HC (2026) — LawSathi Research

Shashikant Pandit Patil and Anr. vs the State of Maharashtra Throu. Govt Pleader and Ors. — Bombay HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

None; petition dismissed with no order as to costs.

Issue for consideration

Whether the High Court should interfere with the order dated 2/1/2024 of the Caste Scrutiny Committee validating Respondent No.4's caste claim as 'Wani' (OBC), which the Petitioners alleged rested on false documents. +1 more

Court's answer

The Scrutiny Committee rightly discarded the document dated 29/9/1914 as unreliable, properly dealt with the documents dated 1/3/1932, 28/6/1946 and the revenue entries, and on the basis of that documentary evidence held that Respondent No.4 belongs to caste 'Wani' (OBC).

Ratio / Principle

Pre-independence documents should be given weightage while deciding caste validity claims, as they have more probative value than post-independence documents; accordingly, the Scrutiny Committee rightly considered the pre-independence documents in this matter.

Key takeaways

In the Court's considered opinion, the members of the Scrutiny Committee rightly accepted the settled legal position (preference for pre-independence documents) and decided the caste claim of Respondent No.4 on that basis.ratio¶34
Following the principles in Kumari Madhuri Patil (supra), the findings recorded by the Scrutiny Committee represent a possible view based upon the evidence; it is therefore not a fit case for the indulgence (interference) of this Court.ratio¶40

Detailed headnote1 paragraphs

High Court of Bombay, Circuit Bench at Kolhapur — Civil Writ Petition No. 5008 of 2024 (decision dated 13-03-2026; oral judgment per Pravin S. Patil, J., bench comprising Madhav J. Jamdar and Pravin S. Patil, JJ.). The Petitioners (two residents of Ahervadi, Taluka South Solapur) challenged the order dated 2/1/2024 of the District Caste Verification Scrutiny Committee, Solapur (Respondent No.3) in Proceeding No. 613/2022, by which the caste claim of Respondent No.4 (Smt. Suvarna Narsappa Dindore alias Suvarna Suryakant Bagale) was validated as 'Wani', recognised under the OBC category. The Petitioners alleged that Respondent No.4 relied on false/manipulated post-independence documents and had earlier asked the Committee to quash the claim. The Vigilance Cell, after School and Home enquiry and recording independent statements, reported on 26/6/2023 recommending that Respondent No.4 belongs to 'Wani'. The Court held that pre-independence documents should be given weightage in caste-validity matters as they carry greater probative value than post-independence documents; the Committee rightly discarded the unreliable document dated 29/9/1914 and relied on the documents dated 1/3/1932 and 28/6/1946 and revenue entries (together with the caste validity certificate of one Yogesh Nagesh Bagale and the family tree). Relying on Kumari Madhuri Patil v. Addl. Commissioner, Tribal Development, (1994) 6 SCC 241, the Court held the Committee's findings to be a possible view based on the evidence, warranting no judicial interference. Petition dismissed with no order as to costs.

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IN THE HIGH COURT OF JUDICATURE AT BOMBAY CIRCUIT BENCH AT KOLHAPUR CIVIL APPELLATE JURISDICTION

CIVIL WRIT PETITION NO. 5008 OF 2024

Shashikant Pandit Patil Age : 36 Years; Occu : Farmer; R/o Ahervadi, Tahsil South Solapur, District Solapur – 413215.

Panchamppa Nimbru Dhanshetty Age : 54 Years; Occu : Business; R/o Ahervadi, Tahsil South Solapur, District Solapur – 413215.

… PETITIONERS

V E R S U S

State of Maharashtra Through Government Pleader

Sub Divisional Oicer, Barshi, District Solapur.

District Caste Veriication Scrutiny Committee, Solapur.

Smt. Suvarna Narsappa Dindore alias Suvarna Suryakant Bagale Age : 49 Years; R/o Ahervadi, Tahsil South Solapur, District Solapur.

… RESPONDENTS

Mr. Ashutosh Purwant, Advocate a/w Mr. Viresh Purwant, Advocate for Petitioners.

Mr. Anant Vadgaonkar, Advocate a/w Ms. Jyoti Kawade, Advocate a/w Mr. Sagar Patil, Advocate a/w Mr. Rushikesh Khupsare, Advocate for Respondent No.4.

Mr. A. A. Naik, AGP for Respondent Nos.1 to 3/State.

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CORAM : MADHAV J. JAMDAR AND PRAVIN S. PATIL, JJ.

DATE : MARCH 13, 2026.

ORAL JUDGMENT : [PER PRAVIN S. PATIL, J.]

. Heard. Rule . Rule made returnable forthwith. With consent of the learned Counsel for both sides, matter is taken up for inal hearing at the stage of admission.

By the present Petition, Petitioners takes exception to the order dated 2/1/2024 passed by the Respondent No.3 – Caste Scrutiny Committee (for short, ‘the Scrutiny Committee’) in the proceeding No. 613/2022, by which, the Scrutiny Committee has validated the claim of Respondent No.4 as ‘Wani’, which is recognized as ‘OBC’ category.

The Petitioners approached before this Court stating that the Respondent No.4, by relying upon the false documents, has claimed veriication of his caste claim before the Scrutiny Committee. It is further stated that initially they have approached to the Scrutiny Committee raising objection that on the basis of false

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documents the Respondent No. 4 is claiming to be belonging to caste ‘Wani’ (OBC) and thereby seeks indulgence of the Scrutiny Committee to quash the caste claim of the Respondent No.4.

In the present matter from the record it is apparent that after submitting caste claim, the Scrutiny Committee has called Vigilance Cell Report. Accordingly, the Vigilance Cell has conducted School and Home enquiry. So also the independent statement in the home enquiry were recorded by the Vigilance Cell and submitted its report dated 26/6/2023 to the Scrutiny Committee recommending thereby that Respondent No.4 belongs to caste of ‘Wani’.

After receipt of the Vigilance Cell Report, members of the Caste Scrutiny Committee have further independently considered all the documentary evidence which were produced before them by the Respondent No.4. The perusal of impugned order demonstrates the fact that the Caste Scrutiny Committee has rightly relied upon the Pre-independence documents, particularly, the documents dated 29/9/1914, 1/3/1932, 28/6/1946 and revenue entries. So also relied

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upon the caste validity certiicate of one Yogesh Nagesh Bagale and the family tree which was produced by the Respondent No.4.

The members of the Scrutiny Committee, after considering the entire evidence and documents available on record, has rightly held that the document dated 29/9/1914 is not reliable document and the same was discarded. However, the documents dated 1/3/1932, 28/6/1946 and revenue entries were properly dealt with and on the basis of this documentary evidence held that Respondent No.4 belongs to caste of ‘Wani’, which is recognized as ‘OBC’.

It is well settled position of law that pre-independence document should be given weightage while deciding caste validity certiicate as same is having more probative value than postindependence document. Accordingly, the Scrutiny Committee has rightly considered pre-independence document in the matter.

The Petitioners, who are the complainant in the present case, challenging the caste validity of the Respondent No.4, has only

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relied upon the post-independence documents. According to them, post-independence documents are manipulated, and therefore, considering these post-independence documents, the Scrutiny Committee ought to have rejected the caste claim of the Respondent No.4.

In view of the catena of Judgments of the Hon’ble Supreme Court of India, it is consistently held that the Scrutiny Committee or the Court while deciding the caste claim should give preference to consider pre-independence document. The reason behind this is that pre-independence documents are not normally manipulated and those documents are having more probative value. Therefore, in our considered opinion, members of the Scrutiny Committee have rightly accepted the legal position and decided the caste claim of the Respondent No.4.

It would be relevant to refer the Judgment of the Hon’ble Supreme Court of India in the case of Kumari Madhuri Patil and Another V/s Addl. Commissioner, Tribal Development and

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Others, (1994) 6 Supreme Court Cases 241, wherein the Hon’ble Supreme Court has held in paragraph 15 as under :

“ 15. The question then is whether the approach adopted by the High Court in not elaborately considering the case is vitiated by an error of law. High Court is not a court of appeal to appreciate the evidence. The Committee which is empowered to evaluate the evidence placed before it when records a inding of fact, it ought to prevail unless found vitiated by judicial review of any High Court subject to limitations of interference with indings of fact. The Committee when considers all the material facts and records a inding, though another view, as a court of appeal may be possible, it is not a ground to reverse the indings. The court has to see whether the Committee considered all the relevant material placed before it or has not d applied its mind to relevant facts which have led the Committee ultimately record the inding. Each case must be considered in the backdrop of its own facts.”

In the facts and circumstances of the case, it is clear that the Scrutiny Committee has taken a possible view in the matter and on the basis of old document decided the caste claim of the Respondent No.4. In view of the settled principles of law, more particularly, the Judgment of the Hon’ble Supreme Court in the case

of Kumari Madhuri Patil (supra), we are of the opinion that indings recorded by the Scrutiny Committee is possible view based

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upon the evidence, and therefore, it is not a it case of indulgence of this Court in the matter. Accordingly, we ind no merit in the present Petition. The same stands dismissed with no order as to costs.

[PRAVIN S. PATIL, J.]

[MADHAV J. JAMDAR, J.]

vijaya

Digitally signed by VIJAYA VIJAYA GOURISHANKAR GOURISHANKAR YADAO YADAO Date: 2026.03.16 20:06:10 +0530