In a significant ruling reinforcing the integrity of caste-based reservations, the Patna High Court refused to interfere with findings that a Panchayat representative had misrepresented his caste status to contest from a reserved seat, holding that inconsistent claims cannot be legally sustained.
The Appellant, elected as Mukhiya from a seat reserved for Extremely Backward Classes, faced a disqualification complaint alleging that he did not belong to the claimed “Dangi” caste. The matter was referred to the Caste Scrutiny Committee, which, after inquiry, concluded that he actually belonged to the “Koeri (Kushwaha)” caste. His writ petition challenging both the reference and the Committee’s findings was dismissed, leading to the present intra-court appeal.
The counsel for the Appellant argued that the State Election Commission lacked jurisdiction to refer the caste issue and that the Scrutiny Committee’s findings were arbitrary, ignoring valid caste certificates issued earlier. He also alleged violation of natural justice, claiming he was denied a fair opportunity to present his case.
On the other hand, the counsel for the Respondents contended that the caste determination was conducted by a competent authority after due consideration of evidence, and that the appellant had taken contradictory stands claiming different caste identities for different benefits.
The Court placed strong reliance on documentary evidence, particularly land revenue records and the appellant’s own prior declarations, noting that such records carry presumption of correctness. It emphasized that a person cannot oscillate between caste identities for personal advantage, observing thata “A person cannot be allowed to oscillate between two caste identities… depending upon the benefit sought to be derived.” The Court further invoked the doctrine against approbation and reprobation, reinforcing that inconsistent positions in law cannot be permitted.
Finding no infirmity in the Single Judge’s ruling or the Scrutiny Committee’s conclusions, the Court dismissed the appeal, holding that the appellant’s claim was legally unsustainable and that no interference was warranted
Case Title: Manoj Prasad v. State Election Commission & Ors.
Case No.: LPA No. 1001 of 2023
Coram: Hon’ble Mr. Justice Sudhir Singh and Hon’ble Mr. Justice Shailendra Singh
Advocate for the Appellant: Mr. S.B.K. Manglam, Mr. Awnish Kumar, Mr. Vikash Kumar Singh
Advocate for the Respondent: Mr. Saroj Kumar Sharma, Mr. Ravi Ranjan, Mr. Girish Kumar, Mr. Santosh Bharti, Mr. Apurva Kumar
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