Punjab & Haryana HC: CBSE ordered to update school certificates after student’s name change

Case Name: Satish Kumar @ Shrey v. Central Board of Secondary Education & Anr.
Date of Judgment: January 10, 2020
Citation: CWP No. 21388 of 2018
Bench: Hon’ble Mr. Justice Sudhir Mittal

Held: The High Court allowed the writ petition and directed the CBSE to correct the petitioner’s name in both the secondary and senior secondary school examination certificates. It held that although CBSE rules permit only correction of clerical or typographical errors, a constitutional court can fill the void where rules do not cater to a particular situation. Since the petitioner had lawfully changed his name through newspaper publication and official Gazette notification, and the change was reflected in Aadhaar and PAN records, CBSE could not deny effect to it.

Summary: The petitioner had passed his Class 10 examination in 2014, with his name recorded as “Satish Kumar.” In 2016, his father decided to change his name to “Shrey.” Following due procedure, the change was published in two local newspapers and in the Chandigarh Administration Gazette dated 01.07.2016. His Aadhaar and PAN cards were updated accordingly.

In 2018, the petitioner requested the CBSE Regional Office to correct his name in the certificates of Class 10 and Class 12, but the request was refused. CBSE argued that its rules only allow correction in case of clerical/typographical errors, not substantive changes in name.

The Court observed that a person’s name is a matter of personal choice and can be changed at any time if due procedure is followed. Since the petitioner had completed all legal formalities and the changed name was already recognized in official records, CBSE was bound to update its certificates. The absence of a specific provision in CBSE rules could not deprive the petitioner of his right.

Decision: The writ petition was allowed. CBSE was directed to correct the petitioner’s name in both the secondary and senior secondary school certificates so that it reads “Satish Kumar @ Shrey”.