VidhiSangh

Supreme Court of India · 12/08/2025

YOGESH MADHAV MAKALWAD versus THE STATE OF MAHARASHTRA & ORS.

[2025] 8 S.C.R. 750 · 2025 INSC 964

AI-generated headnote. Verify against the judgment before relying on it. Paragraph numbers refer to the judgment.

Summary

The Court set aside the invalidation of the appellant's Scheduled Tribe (Koli Mahadev) claim, holding that a pre-Independence 1943 school entry for his grandfather, which the Court itself examined and found free of interpolation, deserved greater probative value than the Scrutiny Committee and High Court gave it, and that failing the affinity test cannot by itself defeat a tribe claim.

Issues

  1. Whether the Scrutiny Committee and the High Court were justified in disbelieving the 1943 school admission and leaving extract of the appellant's grandfather recording his caste as Koli Mahadev.
  2. Whether the appellant's inability to depose to the customs and traditions of the Koli Mahadev tribe (failing the affinity test) was a sufficient ground to invalidate his caste claim.
  3. Whether the absence of any previously validated caste certificate in the family justified rejection of the claim.

Held

Result

Appeal allowed; High Court judgment dated 23 July 2024 quashed and set aside; appellant held to belong to the Koli Mahadev Tribe; Scrutiny Committee directed to issue a Caste Validity Certificate within six weeks.

Judgment PDF: Supreme Court of India, [2025] 8 S.C.R. 750.