Court holds violation of natural justice in enquiry; directs District Level Scrutiny Committee to conduct fresh verification while emphasizing claimant's burden of proof for caste status
In a significant judgment delivered on October 16, 2026, the Andhra Pradesh High Court (Division Bench) allowed appeals filed by the State Bank of India (SBI) challenging a Single Judge's order that had set aside the cancellation of caste certificates of two brothers, P. Rama Chandraiah and P. Rama Krishnaiah, and their consequent dismissal from service.
The case arose when SBI received an anonymous complaint alleging that the petitioners had obtained employment by producing false Scheduled Caste (SC) certificates. Pursuant to this, the District Collector initiated an enquiry into their caste status, which resulted in the cancellation of their caste certificates on the ground that they belonged to the `Balija' community, a non-SC group. Following this, the bank dismissed the petitioners from service.
The petitioners challenged the cancellation and dismissal before the High Court through writ petitions. The Single Judge found that the enquiry violated principles of natural justice as crucial documents such as the enquiry report and the anonymous complaint were not furnished to the petitioners. Consequently, the Single Judge set aside the cancellation orders and reinstated one petitioner while granting terminal benefits to the other.
However, the Division Bench, comprising Justices D. Ramesh and Alapati Giridhar, reversed the Single Judge's order. The Bench emphasized that while the enquiry was indeed vitiated by non-furnishing of documents, the appropriate remedy was not outright setting aside of cancellation or automatic reinstatement. Instead, the matter must be remanded to the competent authority-the District Level Scrutiny Committee-for fresh adjudication from the stage where the defect occurred.
The Court underscored the burden of proof under Section 6 of the Andhra Pradesh (Scheduled Castes, Scheduled Tribes and Backward Classes) Regulation of Issue of Community Certificates Act, 1993, which lies on the claimant to establish their caste status through comprehensive evidence such as detailed family trees, educational records, employment particulars, and caste certificates of ancestors and relatives. It further highlighted the duty of authorities to conduct thorough verification including electronic and social media evidence.
Importantly, the Court noted that benefits obtained on the basis of false caste certificates are liable to be withdrawn under Section 11 of the Act, and criminal prosecution may follow, including examination of caste certificates of family members.
The Bench directed the petitioners to appear before the District Level Scrutiny Committee, which was instructed to furnish all relevant documents including the enquiry report and provide the petitioners an opportunity to submit evidence supporting their claim. The committee was mandated to conclude the fresh inquiry expeditiously within three months.
Clarifying the scope of its order, the High Court made it clear that it had not expressed any opinion on the merits of the petitioners' caste status and the authorities must proceed uninfluenced by previous observations.
This judgment reinforces procedural safeguards in caste verification enquiries, emphasizes the importance of fair hearing, and the necessity for meticulous scrutiny to uphold the integrity of affirmative action policies.
Bottom Line:
Community certificate verification - Where cancellation of caste certificates and consequential dismissal from service are set aside on the ground of violation of principles of natural justice due to non-furnishing of enquiry report and relied documents, proper course is remand to the competent scrutiny/disciplinary authority from the stage of defect, and not reinstatement or grant of terminal benefits straightaway - Burden of proof to establish caste status lies on the claimant.
Statutory provision(s):
Andhra Pradesh (Scheduled Castes, Scheduled Tribes and Backward Classes) Regulation of Issue of Community Certificates Act, 1993, Section 6, Section 11
State Bank of India v. P Rama Chandraiah, (Andhra Pradesh)(DB) : Law Finder Doc Id # 2999035
