The Bombay High Court has ruled that authorities cannot deny admission under the Right to Education (RTE) Act merely because a deceased father's caste certificate is unavailable when the child's mother is the sole surviving parent and possesses a valid caste certificate. The Court set aside orders rejecting the child's admission and directed the authorities to grant admission without insisting on the father's caste certificate.
Background of the Case
The petition was filed by Ranjana Yogesh Jadhav, a house help from Pune and a single mother, after education authorities refused RTE admission to her daughter, Arohee Yogesh Jadhav, in Aditya English Medium School. The rejection was based solely on the ground that the caste certificate of the child's late father had not been produced.
Ranjana informed the Court that both she and her late husband belonged to the Dhangar community, a recognised Nomadic Tribe. While she had produced her own valid caste certificate, her husband had passed away in December 2021 before obtaining one. She also relied on his school leaving certificate, which recorded his caste as Dhangar. Despite this, the Taluka Level Scrutiny Committee, the Education Officer and the Deputy Director (Education) rejected her claim.
Court's Observations
Justice N. J. Jamadar observed that what appeared to be a procedural issue actually affected the child's constitutional right to free and compulsory education as well as the principle of equality.
The Court noted that authorities had taken an excessively technical approach by insisting only on the father's caste certificate even though he had died and the mother was the child's sole parent.
The bench observed,
“The insistence on the child being recognized, in all circumstances, solely by the caste of her father is not sustainable.”
Referring to Supreme Court decisions, the High Court said that a child is not legally bound in every situation to inherit only the father's caste. In appropriate circumstances, particularly where the mother is the natural guardian and the child shares her social background, the mother's caste can be relied upon.
The Court further found that the authorities ignored relevant evidence, including the father's authenticated school leaving certificate showing that he belonged to the Dhangar community. During the hearing, the Court directed verification of the certificate, and the school confirmed its authenticity.
Justice Jamadar remarked that denying admission under the RTE quota in these circumstances reflected a "myopic and constricted view" and allowed procedural rigidity to override the child's constitutional rights.
Court's Decision
Allowing the writ petition, the Bombay High Court quashed the orders of the Deputy Director (Education) and the Education Officer that had upheld the rejection of the child's admission.
The Court directed the respondents to immediately grant admission to Arohee Yogesh Jadhav under the RTE quota without insisting on her deceased father's caste certificate, and ordered that the admission be completed on or before 31 July 2026.
Case Details
Case Title: Ranjana Yogesh Jadhav v. Principal Secretary, School Education Department & Ors.
Case Number: Writ Petition No. 7647 of 2026
Judge: Justice N. J. Jamadar
Decision Date: 22 July 2026
