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As per case facts, Respondent No. 1 secured a caste certificate as 'Halba' Scheduled Tribe for medical admission, but the Scrutiny Committee and appellate authority invalidated it, asserting he belonged
...to 'Koshti' caste. The High Court, however, allowed his writ petition, holding that 'Halba-Koshti' could be considered a sub-tribe of 'Halba/Halbi', leading the State of Maharashtra to appeal. The question arose whether it is permissible to conduct an inquiry and admit evidence to declare a tribe or community as included in the Constitution (Scheduled Tribes) Order, 1950, when not specifically mentioned, and specifically, if 'Halba Koshti' is a sub-tribe of 'Halba/Halbi' under Entry 19 for Maharashtra. Finally, the Supreme Court, upholding its previous Constitution Bench rulings, unequivocally held that no inquiry or evidence is permissible to establish inclusion in the Scheduled Tribes Order if not expressly mentioned. It emphasized that only Parliament, through legislation, can amend or modify the Presidential Orders issued under Articles 341 and 342, precluding State Governments, courts, or other authorities from doing so. The High Court's reliance on conflicting Division Bench judgments and misapplication of stare decisis was deemed erroneous. Consequently, the Court found that 'Halba-Koshti' is not a sub-tribe of 'Halba/Halbi' as it is not explicitly listed in the Order, answering both questions in the negative. However, acknowledging the passage of time and the respondent's completed medical education, the Court clarified that this judgment would not retrospectively impact his degree or past admissions/appointments, but he would not be entitled to future Scheduled Tribe benefits.
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