The Supreme Court ruled that a caste certificate issued under the Kerala (Scheduled Castes and Scheduled Tribes) Regulation of Issue of Community Certificates Act, 1996, cannot be challenged in an election petition unless expressly permitted by statute. The burden of proof remains on the election petitioner to establish disqualification beyond reasonable doubt. The Court held that allegations of conversion must be proved conclusively, and mere rituals do not determine religious status. The judgment reaffirmed that election petitions require strict compliance with pleadings and evidence standards akin to criminal proceedings. The High Court’s decision was overturned for shifting the burden incorrectly and relying on unsubstantiated claims.
Facts Of The Case:
The case involves an appeal before the Supreme Court of India under Section 116-A of the Representation of the People Act, 1951, challenging the High Court of Kerala’s judgment that declared the election of the appellant, A. Raja, from the Devikulam Legislative Assembly Constituency (reserved for Scheduled Castes) as void. The respondent, D. Kumar, contested the election, alleging that Raja was not a member of the Scheduled Castes in Kerala but was instead a Christian, thus ineligible to contest from a reserved constituency. The High Court accepted Kumar’s argument, ruling that Raja’s ancestors had migrated from Tamil Nadu to Kerala after 1950 and were not permanent residents of Kerala as required under the Constitution (Scheduled Castes) Order, 1950. Additionally, the High Court found that Raja and his family had converted to Christianity, further disqualifying him from claiming Scheduled Caste status.
Raja appealed, asserting that his ancestors were residents of Kerala before 1950 and that he had not converted to Christianity. The Supreme Court examined the evidence, including caste certificates and baptism records, and concluded that the High Court erred in shifting the burden of proof to Raja and in relying on unsubstantiated claims of conversion. The Court allowed the appeal, reinstating Raja’s election and emphasizing the need for strict adherence to legal standards in election petitions.
Procedural History:
The case originated from an election petition filed by D. Kumar before the High Court of Kerala, challenging A. Raja’s election from a reserved Scheduled Caste constituency on grounds of ineligibility. The High Court declared Raja’s election void under Section 100(1)(a) and (d)(i) of the Representation of the People Act, 1951, holding that he did not belong to the Hindu Parayan caste in Kerala and had converted to Christianity. Raja appealed to the Supreme Court under Section 116-A of the Act.
The Supreme Court granted a conditional stay on the High Court’s judgment, allowing Raja to participate in legislative proceedings but restricting his voting rights. After hearing arguments, the Supreme Court overturned the High Court’s decision, ruling that the caste certificate could not be challenged in an election petition and that the burden of proof was improperly placed on Raja. The appeal was allowed, restoring Raja’s election with consequential benefits.
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Court Observation:
The Supreme Court made several key observations in its judgment. It emphasized that caste certificates issued under statutory provisions cannot be invalidated through an election petition unless expressly permitted by law, upholding the sanctity of due process under the Kerala (Scheduled Castes and Scheduled Tribes) Act, 1996. The Court reiterated that election petitions must meet stringent evidentiary standards akin to criminal proceedings, requiring allegations to be proved beyond reasonable doubt. It rejected the High Court’s reliance on unsubstantiated claims of religious conversion, noting that mere participation in rituals does not establish a change in professed religion under the Constitution (Scheduled Castes) Order, 1950.
The Court also clarified that the burden of proof rests on the election petitioner to demonstrate disqualification and criticized the High Court for erroneously shifting this burden to the returned candidate. Additionally, it underscored that pleadings in election petitions must be precise and supported by concrete evidence, aligning with precedents like M. Chandra v. M. Thangamuthu and Kalyan Singh Chouhan v. C.P. Joshi. The judgment reinforced that challenges to caste status must follow statutory mechanisms rather than election petitions, ensuring procedural integrity in such disputes.
Final Decision & Judgement:
The Supreme Court allowed the appeal, setting aside the High Court’s judgment and restoring A. Raja’s election as a validly elected member of the Kerala Legislative Assembly. The Court held that the respondent failed to discharge the burden of proving Raja’s disqualification beyond reasonable doubt, as required in election petitions. It ruled that caste certificates issued under statutory authority cannot be collaterally challenged in election proceedings absent legislative mandate, reaffirming the primacy of scrutiny mechanisms under the Kerala (Scheduled Castes and Scheduled Tribes) Act, 1996.
The Court clarified that allegations of religious conversion require rigorous evidentiary substantiation, which was lacking in this case. Consequently, the election petition was dismissed, and Raja was declared entitled to all consequential benefits as an MLA from the date of his oath. The judgment underscored that electoral disputes must strictly adhere to statutory frameworks and evidentiary standards, preserving the integrity of both reservation policies and democratic representation. No costs were awarded.
Case Details:
Case Title: A. Raja v. D. Kumar Citation: (2025) INSC 804 Appeal No: Civil Appeal No. 2758 of 2023 Date of Judgment: May 6, 2025 Judges/Justice Name: Justice Abhay S. Oka & Justice Ahsanuddin Amanullah & Justice Augustine George Masih
Download The Judgement Here