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Bombay High Court

ADITYA SANJAY KUMAR KOLIversusSTATE OF MAHARASHTRA THRO. ITS SECRETARY TRIBAL DEVELOPMENT DEPT.

Decided
Disposal
Disposed Off

Holding

The Court set aside the impugned judgment and ordered the Scrutiny Committee to reconsider the petitioner’s caste claim de novo in light of the new documents.

Summary

The petitioner, Aditya Sanjaykumar Koli, filed a writ petition seeking to quash a September 2024 order of the Scrutiny Committee that invalidated his caste certificate as a Mahadev Scheduled Tribe Koli. Earlier proceedings had seen his father’s caste claim dismissed, the petition dismissed by this Court, the Special Leave Petition rejected by the Supreme Court, and a review petition dismissed, with a curative petition pending. The petitioner later submitted an additional affidavit containing pre‑constitutional documents showing his paternal relatives as Mahadev Koli, which were not previously produced before the Scrutiny Committee. The Court held that, despite the earlier invalidation, the new evidence warranted a fresh, de novo consideration and therefore set aside the impugned order, remanding the matter to the Scrutiny Committee for a new decision within two months, granting the petitioner a hearing. The petition was disposed of without any order as to costs.

Issues considered

  • What is the effect of newly produced documentary evidence on a previously invalidated caste certificate claim?
  • Whether the High Court can set aside the Scrutiny Committee’s order and remand the matter for de novo consideration?

Subjects

  • caste certificate
  • Scrutiny Committee
  • de novo review
  • Mahadev Koli
  • Scheduled Tribe
  • curative petition
  • writ petition
  • remand

Judgment

                                                                              910-WP-14466-25.doc


             Sharayu Khot.

                               IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                       CIVIL APPELLATE JURISDICTION

                                      WRIT PETITION NO. 14466 OF 2025


                    Aditya Sanjaykumar Koli                         …Petitioner

                             Versus

                    State of Maharashtra & Ors.                     …Respondents

                                                     ----------
                    Mr. R.K. Mendadkar a/w Mr. Jagadish C. Kawale for the Petitioner.
                    Mr. P.P. Kakade, Addl.GP with Ms. D.S. Deshmukh, AGP for the
                    Respondent-State,
                                                     ----------

                                              CORAM : R.I. CHAGLA J
                                                      FIRDOSH P. POONIWALLA, J

                                              DATE       : 20 August 2026

                    ORDER :


                    1.            By this Petition, the Petitioner has sought quashing and

                    setting aside of the impugned judgment and order dated 20th

                    September 2024 passed by Respondent No. 2 Scrutiny Committee,

SHARAYU
PANDURANG
KHOT
                    invalidating the Caste Certificate of the Petitioner as belonging to Koli

Digitally
signed by
                    Mahadev Scheduled Tribe issued by Competent Authority of
SHARAYU
PANDURANG
KHOT
Date:
2026.08.24
17:58:34
+0530
                    jurisdiction, with further direction to issue Caste Validity Certificate

                    in favor of the Petitioner in light of the adjudication rendered by this


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Court.



2.           We have heard the learned Counsel for the parties as

well as perused the interim order dated 7th November 2025 by which

this Court observed that the Petitioner's father Sanjaykumar Koli's

caste claim had been invalidated by the Scrutiny Committee and the

Writ Petition challenging the invalidation had been dismissed by this

Court as well as, the Special Leave Petition therefrom had been

dismissed by the Supreme Court. Further, the Review Petition has

also been dismissed for which a curative Petition is pending. Having

so observed, this Court issued rule and did not grant interim relief.



3.           Thereafter, an additional Affidavit has been filed in

Support of the Writ Petition in which, the Petitioner has placed

reliance upon documents which were not produced before the

Respondent No. 2 Scrutiny Committee, and which pertain to pre-

constitutional documents showing the paternal blood relatives’ caste

as ‘Mahadev Koli’. It is the contention of Respondent No. 2 Scrutiny

Committee itself that these documents have been produced for the

first time before this Court.




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4.          We accordingly, consider it appropriate, notwithstanding

the fact that the caste claim of the Petitioner's father had been

invalidated, to remand the matter back to the Respondent No. 2

Scrutiny Committee for a fresh consideration of the caste claim of the

Petitioner in light of these documents. It is also pertinent to note that

these documents were not produced in the proceedings of the

Petitioner's father as well as his grandfather and brother whose caste

claims have been invalidated.



5.          We accordingly, remand the matter back to the

Respondent No. 2 Scrutiny Committee by setting aside the impugned

judgment and order dated 20th September 2024.



6.          The Respondent No. 2 Scrutiny Committee shall decide

the caste claim of the Petitioner de novo by considering the material

on record including the new documents which the Petitioner has

relied upon and annexed to the additional Affidavit filed in Support

of the Petition within a period of two months from the date of this

order.



7.          An opportunity of hearing shall also be granted to the

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Petitioner prior to the passing of the said decision.



8.           We accordingly, dispose of the present Petition in these

terms. There shall be no order as to costs.




      [FIRDOSH P. POONIWALLA, J.]                   [R.I. CHAGLA J.]




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