Caste Scrutiny Committee Cannot Sit As Appellate Authority Over Its Own Vigilance Cell: MP High Court

The Madhya Pradesh High Court has quashed the cancellation of a serving police officer’s Scheduled Tribe caste certificate, holding that a state scrutiny committee had no power to proceed once two independent vigilance reports found his claim genuine.

Justice Vivek Kumar Singh, sitting at Jabalpur, allowed the writ petition filed by Amrat Lal Meena against the 9 December 2025 order of the Madhya Pradesh State Level High Powered Caste Scrutiny Committee. The Court restored his ‘Meena’ Scheduled Tribe certificate, issued on 29 October 1991 by the Tehsildar of Lateri in Vidisha district.

The dispute stems from a geographical anomaly. Before the 1956 reorganisation of States, Sironj Sub-Division, comprising Sironj and Lateri tehsils, belonged to Rajasthan, where Meenas are a Scheduled Tribe. After it merged into Vidisha, the community stayed notified as a Scheduled Tribe only in that sub-division, while elsewhere in Madhya Pradesh it is classed as Other Backward Classes. A 2002 amendment, effective 8 January 2003, removed the Sironj Meenas from the Scheduled Tribe list.

Meena ranked 25th in the 1995 State Services Examination for Deputy Superintendent of Police. His appointment was held back for nearly two years for verification, and he joined on 27 February 1999. Complaints questioning his certificate began in 2007, and a CID inquiry closed the first in 2010. Fresh complaints led the Committee to cancel it in 2016, but a coordinate bench quashed that order in September 2024 and ordered a fresh, independent scrutiny.

The Committee then asked the Superintendents of Police of Vidisha and Guna to investigate on the spot. Both reports, dated 14 October 2025 and 12 November 2025, favoured Meena. Yet the Committee discarded them as resting mainly on oral evidence and cancelled the certificate again.

Senior Advocate Manoj Kumar Sharma, with advocates Quazi Fakhruddin and Vaishnavi Rao, argued for Meena that the Supreme Court’s Madhuri Patil guidelines and a 1997 State circular bar further action once a vigilance report is favourable, unless it was procured by fraud. Deputy Advocate Generals Swapnil Ganguly and Shweta Yadav defended the order for the State, saying the reports ignored school records and pre-1950 revenue documents.

Senior Advocate M.P.S. Raghuvanshi, appearing by video conferencing with advocate Pramod Singh Tomar, sought to intervene. The Court dismissed all three intervention applications, holding that the applicants were strangers who had suffered no legal injury. Relying on Ravi Yashwant Bhoir and Ayaaubkhan Noorkhan Pathan, it said a complainant can at most be a witness, not an adversarial litigant.

On the merits, the Court said it was not sitting as an appellate court over the evidence, only examining whether the Committee followed the mandatory procedure. It found that it did not.

The Court noted there was “not even a whisper of a finding” that either vigilance report was procured or fraudulently obtained. Without it, the Committee “had no jurisdiction to sit as an appellate authority over its own Vigilance Cell.”

The Court also rejected the Committee’s criticism that the reports lacked old records. Both had inspected Meena’s clan deity shrine and recorded villagers’ testimony, it noted, while the State’s own Collectorate had destroyed the older revenue records in 2005. “The law does not compel a citizen to perform the impossible,” the Court said.

The bench was equally critical of the Committee’s change of course. Having resolved to ignore earlier inquiries, it “took about turn” when the fresh reports favoured Meena and fell back on a 2014 CID compilation already quashed. It also stayed silent on his jurisdictional objection.

Calling the cancellation, after 27 years of service including the President’s Police Medal for Gallantry and on the eve of his induction into the Indian Police Service, “malice in law”, the Court declined a second remand. It held that “the only lawful course open to respondent No. 4 was to drop and close the proceedings.”

The impugned order and all consequential proceedings were set aside, the certificate restored, and no costs imposed.

Case Title: Amrat Lal Meena @ Amrat Meena vs. State of Madhya Pradesh & others

Order Date: October 28, 2026

Bench: Justice Vivek Kumar Singh