The High Court dismissed a writ petition challenging the decision of the Caste Scrutiny Committee to invalidate the petitioner's claim of belonging to the "Mana" Scheduled Tribe. The court emphasized the importance of pre-independence documents, where the petitioner’s ancestors were listed as "Mani," "Bhormani," "Mane," and "Mani Kunbi," rather than "Mana." The petitioner's reliance on her father's and cousin's validity certificates was also deemed unhelpful due to findings of falsified documentation during the inquiry. The court relied on prior judgments stating that similar or synonymous names cannot be used to claim Scheduled Tribe status, affirming the Committee's decision.

1. Challenge to Committee’s Order:
   The petitioner contested the Caste Scrutiny Committee's decision, dated 28/08/2023, which rejected her claim of belonging to the "Mana" Scheduled Tribe. The rejection followed the Committee’s assessment of pre-constitutional era documents that identified her ancestors as belonging to "Mani," "Bhormani," "Mane," and "Mani Kunbi" rather than "Mana."

2. Petitioner’s Evidence:
   The petitioner provided eleven documents, five of which were from the pre-constitutional period (1903-1948). These documents listed her great-great-grandfather, great-grandfather, and other ancestors as belonging to non-Mana castes. Despite this, she contended that these entries should be read as “Mana” based on similar names.

3. Vigilance Cell Report:
   The Vigilance Cell's investigation revealed adverse entries from 1903 to 1959, identifying the petitioner's ancestors as belonging to "Mani," "Bhormani," and "Mane Kunbi," contradicting her claim. The petitioner failed to refute these findings.

4. Legal Precedent:
   The petitioner relied on the Supreme Court judgment in Priya Pramod Gajbe v. State of Maharashtra (2023), arguing that "Mani" and "Mane" should be read as "Mana." However, the court distinguished her case from Priya Gajbe, emphasizing that similar or synonymous names cannot be interpreted to claim "Mana" Scheduled Tribe status, as reaffirmed in the Full Bench decision in Maroti Vyankati Gaikwad v. Deputy Director & Member-Secretary (2023).

5. Reliance on Family Validity Certificates:
   The petitioner argued that her father and cousin had previously been granted validity certificates as "Mana" Scheduled Tribe members. However, the court found these certificates to be based on a false document and held that they were not relevant to her case.

6. Court’s Conclusion:
   The court ruled that the petitioner failed to discharge the burden of proof required under Section 8 of the Maharashtra Scheduled Castes, Scheduled Tribes, Denotified Tribes (Vimukta Jatis), Nomadic Tribes, Other Backward Classes and Special Backward Category (Regulation of Issuance and Verification of) Caste Certificate Act, 2000, and upheld the Caste Scrutiny Committee's decision to invalidate her claim.

Acts and Sections Discussed:

1. The Maharashtra Scheduled Castes, Scheduled Tribes, Denotified Tribes (Vimukta Jatis), Nomadic Tribes, Other Backward Classes and Special Backward Category (Regulation of Issuance and Verification of) Caste Certificate Act, 2000:
   • Section 8: Places the burden of proof on the claimant to demonstrate that they belong to a Scheduled Tribe. The petitioner failed to meet this burden.

Ratio Decidendi:
Pre-independence documents have greater probative value in determining caste claims. The court upheld that the caste recorded in historical documents is determinative unless proven false. Synonymous or similar names cannot be used to claim inclusion in a Scheduled Tribe unless explicitly stated in the Presidential Order. The burden of proof lies on the petitioner, who must provide convincing evidence to refute adverse entries, which the petitioner failed to do in this case.

Subjects:
Mana Scheduled Tribe, Caste Scrutiny Committee, Vigilance Cell Report, Caste Verification, Maharashtra Caste Certificate Act, 2000, Scheduled Tribe Claim, Historical Documents, Pre-Independence Era Evidence.