What’s In A Name | Rajasthan High Court Says Mother Has Every Right To Be Named On Child’s Academic Record | Denial Of Identity Is Denial Of Personhood
Safiya Malik
The High Court of Rajasthan Single Bench of Justice Anoop Kumar Dhand disposed of a writ petition concerning the correction of a mother’s name in a student’s academic certificates. The court granted liberty to the petitioner to submit a fresh application accompanied by a verified affidavit through the school authorities and directed the Board of Secondary Education, Rajasthan, to make the necessary corrections upon such submission. The bench ordered that the entire process, including issuance of corrected certificates, be completed within three months from the date of receipt of the certified copy of the order.
The case involved a petition filed by a student who had passed the Secondary and Senior Secondary examinations conducted by the Board of Secondary Education, Rajasthan. The petitioner’s grievance arose from an error in his Class 10th and Class 12th academic certificates, where his mother’s pet name, “Tina Naruka,” was mentioned instead of her official name, “Asha Naruka.”
According to the petitioner, his mother is affectionately called “Tina” within the family, which inadvertently led to her nickname being recorded in the official school documents. The petitioner submitted that in all other legal and government-issued documents—including his birth certificate, domicile certificate, Aadhar Card, Jan Aadhar Card, ration card, and the marriage certificate of his parents—his mother’s name is correctly mentioned as “Asha Naruka.”
Seeking rectification of the error, the petitioner filed an application with the Board of Secondary Education, Rajasthan, on 25 July 2022. This application included an affidavit and supporting documents. However, the Board rejected the application through an order dated 4 August 2022, prompting the petitioner to approach the High Court.
In his writ petition, the petitioner prayed for setting aside the impugned order and for directions to correct his mother’s name in the academic documents. The specific reliefs sought were: quashing of the order dated 4 August 2022, correction of his mother’s name in the Class 10th and Class 12th mark sheets and migration certificate, and any other order deemed appropriate by the Court.
Counsel for the petitioner argued that denying such a correction based on a procedural lapse was unjustified, especially when documentary evidence clearly established the correct name of the mother as “Asha Naruka.”
Opposing the petition, the Board contended that the application for name correction had not followed the required procedure outlined in its Office Order dated 26 February 2021. According to the said procedure, such applications must be submitted on plain paper along with an affidavit and should be verified by the Headmaster or Principal of the school from which the candidate passed the relevant examination. The respondents stated that the petitioner had failed to obtain this verification, and hence, the application was returned with objections.
The court took note of the arguments and documents on record and proceeded to examine whether procedural requirements could override the petitioner’s right to accurate academic documentation, especially concerning a parent’s identity.
Justice Anoop Kumar Dhand recorded, “A name is an intrinsic element of identity... To name someone is to recognize their presence in the world and to be nameless, in many ways, is to be invisible.”
The judgment stated, “To mispronounce, ignore or intentionally change someone’s name is to deny them their identity... A name is memory, dignity, identity and self-worth.”
The court observed, “A mother’s name in educational record is more than just a detail, it’s a thread that weaves a child’s identity, and sense of belonging.”
It further recorded, “Prior to the year 2001, there was no concept of adding name of mother in the educational records... it is clearly retrogressive if the educational certificates reflect only the name of father of a candidate eliminating the name of the mother.”
Addressing the facts of the case, the court stated, “In the instant case, though the correct name of the petitioner is there in his educational record... by mistake, the pet name of his mother is mentioned therein.”
The bench noted, “It appears that in the instant case instead of following the above process and without getting the aforesaid verification by the Headmaster/Principal of the school/educational institution, the petitioner has straightaway approached the Board.”
Recognizing the petitioner’s efforts and the substantial evidence provided, the court observed, “Considering the arguments... and looking to the fact that the matter pertains to correction of name of mother... the only objection taken by the Board is that such application should be submitted... duly verified by the Head Master/Principal.”
The court stated the principle that procedural compliance must not obstruct rightful correction of personal identity in educational records.
The High Court, after assessing the facts and the procedural shortcoming, disposed of the writ petition by granting liberty to the petitioner to submit an appropriate application along with an additional affidavit before the respondents, after obtaining verification from the Headmaster or Principal of the school from which the petitioner passed his Class 10th and Class 12th examinations.
Upon such verification and submission of a fresh application, the Court directed the Board to make the necessary corrections in the petitioner’s Class 10th and Class 12th mark-sheets and to issue fresh certificates.
The Court further directed that the entire exercise be completed by the petitioner and the respondents within a period of three months from the date of receipt of the certified copy of the order. All pending applications, if any, were also ordered to stand disposed of.
Advocates Representing the Parties
For the Petitioner: Mr. Rahul Sharma
For the Respondents: Mr. Parth Vashishtha for Mr. Shantanu Sharma
Case Title: Chirag Naruka v. The Chairman, Board of Secondary Education, Rajasthan Ajmer & Ors.
Neutral Citation: 2025:RJ-JP:20640
Case Number: S.B. Civil Writ Petition No.13360/2022
Bench: Justice Anoop Kumar Dhand
[Read/Download order]
