Karnataka High Court Quashes Unauthorized Caste Certificate Investigation

Civil Rights Enforcement Cell lacked authority for suo motu probe; Orders release of withheld terminal benefits to retired teacher.

In a significant ruling on November 18, 2025, the Karnataka High Court, Dharwad Bench, presided over by Justice M. Nagaprasanna, set aside proceedings initiated by the Civil Rights Enforcement Cell against Sri. T.H. Hosamani concerning the validity of his caste certificate. The court emphasized that the Civil Rights Enforcement Cell lacked the jurisdiction to conduct a suo motu investigation, as such authority is contingent upon a referral from the District Caste Verification Committee, as mandated by the Karnataka Scheduled Castes, Scheduled Tribes, and Other Backward Classes (Reservation of Appointments, Etc.) Rules, 1992.

The petitioner, Sri. T.H. Hosamani, had secured employment as an Assistant Teacher and later a promotion to Headmaster, based on a caste certificate identifying him as belonging to the Bhovi caste, a Scheduled Caste. A complaint was later lodged by a respondent alleging that Hosamani had falsified his caste identity. Acting on this complaint, the Civil Rights Enforcement Cell initiated an investigation without a requisite referral from the District Caste Verification Committee, leading to the cancellation of Hosamani’s caste certificate and the registration of a criminal case, from which he was subsequently acquitted.

Justice Nagaprasanna highlighted that the actions taken by the Civil Rights Enforcement Cell were in direct violation of Rule 7(4) of the 1992 Rules, which explicitly requires a referral for any investigation into caste certificates. The court ruled that all proceedings and actions stemming from the unauthorized investigation were null and void, thus reinstating the validity of Hosamani's caste certificate. Furthermore, the court ordered the immediate release of Hosamani's withheld terminal benefits, recognizing that these had been unjustly denied based on invalid orders.

This judgment reinforces the principles of natural justice and the necessity for adherence to statutory procedures. The court also cautioned that the caste certificate should not be used by any of Hosamani's family members for claiming Scheduled Caste benefits.

Bottom Line:

Civil Rights Enforcement Cell does not have the power to take up suo motu investigation into caste certificates - Its action must be based on a reference made by the District Caste Verification Committee as per the Karnataka Scheduled Castes, Scheduled Tribes and Other Backward Classes (Reservation of Appointments, Etc.) Rules, 1992.

Statutory provision(s): Karnataka Scheduled Castes, Scheduled Tribes and Other Backward Classes (Reservation of Appointments, Etc.) Rules, 1992, Rule 7(4)

Sri. T.H. Hosamani v. State of Karnataka, (Karnataka)(Dharwad) : Law Finder Doc Id # 2812455