1. Petitioner: Narsingrao s/o Nivruttirao Udgirkar filed Election Petition No. 3 of 2024, challenging the election of Respondent No. 1, Dr. Shivaji Bandappa Kalge, from the 41-Latur (SC) Parliamentary Constituency.

2. Grounds for Petition: The petitioner claimed that Dr. Shivaji Kalge falsely declared himself to belong to the “Mala Jangam” Scheduled Caste category, which qualified him to contest a seat reserved for the Scheduled Castes.

3. Caste Scrutiny: The petition alleged that Dr. Shivaji's caste certificates and validity certificates were obtained fraudulently, supported by documents like school records and village registers that showed inconsistencies in caste designations.

4. Respondent's Stand: Dr. Shivaji Kalge produced a caste certificate and caste validity certificate granted by the Caste Scrutiny Committee, which was relied upon by the Returning Officer during scrutiny. The Returning Officer accepted his nomination and rejected objections during the election process.

5. Legal Precedents: The Court referred to past judgments, including Mohan Rawale v. Damodar Tatyaba, which states that even weak election petitions should be heard if they disclose some cause of action.

6. Court’s Ruling: The Court ruled that the caste certificate and caste validity certificate issued by the Caste Scrutiny Committee, a quasi-judicial authority, cannot be questioned unless fraud or jurisdictional errors are established. Since the petitioners failed to provide sufficient material facts or pleadings to prove fraud, the election petitions were dismissed under Order VII, Rule 11 of the Civil Procedure Code.

Acts and Sections Discussed:

1. Representation of People Act, 1951:

   • Section 4(a): Qualification for membership based on caste status.
   • Section 100(1)(a): Grounds for declaring an election void if the candidate is disqualified on the date of election.

2. Maharashtra Scheduled Caste, Scheduled Tribes, De-notified Tribes, Nomadic Tribes, Other Backward Classes and Special Backward Category (Regulation of Issuance and Verification of) Caste Certificate Act, 2000: Procedures for issuing and verifying caste certificates.

3. Order VII, Rule 11 of the Civil Procedure Code: Grounds for rejection of election petitions lacking material facts.

Ratio Decidendi:

The Court emphasized that the Caste Scrutiny Committee is the competent authority to decide caste status. Unless a petitioner can provide clear evidence of fraud or procedural irregularities, its decision cannot be overturned by the Court in an election petition. The omission of material facts in the election petitions resulted in their dismissal.

Subject:

Election Law, Caste Certificate, Scheduled Caste Reservation, Representation of People Act, Civil Procedure, Quasi-judicial Authority.