Rajasthan High Court: In a civil writ petition seeking correction of petitioner’s mother name in his academic records (Class 10 and Class 12 marksheets and migration certificate) issued by the Board of Secondary Education, Rajasthan, a single-judge bench of Anoop Kumar Dhand, J., while upholding procedural discipline, placed strong emphasis on the dignity and identity associated with a mother’s name in a child’s academic records. The Court disposed of the petition with liberty to the petitioner to re-submit his application for name correction, this time complying with the procedural requirement of obtaining verification from the Headmaster/Principal of the concerned school.
In the instant matter, the petitioner passed his Secondary examination (2019) and Senior Secondary examination (2021) under the Board of Secondary Education, Rajasthan. However, his mother’s name was incorrectly recorded as “Tina Naruka” instead of her correct name “Asha Naruka” in his educational certificates. The error occurred because “Tina” is a nickname used within the family.
Despite submitting an application for correction on 25-07-2022 along with an affidavit and supporting documents including birth certificate, domicile, Aadhar, Jan Aadhar, ration card, and marriage certificate of his parents, the Board rejected the application via order dated 04-08-2022. Aggrieved by the rejection, the petitioner to approach this Court challenging the impugned order.
The petitioner submitted that the petitioner’s mother’s name is correctly recorded as “Asha Naruka” in all official documents. The incorrect entry of “Tina Naruka” was inadvertent and based on a nickname. It was further argued that the mother, as the birth-giver and fundamental figure in a child’s life, has an inherent right to be correctly named in the child’s academic records. The petitioner complied with the substantive requirement by submitting all relevant documents.
However, the respondents contended that the application lacked proper procedural compliance, particularly the verification by the Headmaster or Principal of the school last attended, as required under the Board’s Office Order dated 26-02-2021 and on this technical ground, the application was rejected.
Beginning with the rhetorical line, “What is there in the name?”, the Court emphasised that a name is an “intrinsic element of identity” and “a legal marker of existence.” Quoting Shakespeare and expanding upon the psychological and emotional resonance of naming, the Court stated that —
“To mispronounce, ignore or intentionally change someone’s name is to deny them their identity… So what’s in a name is everything. A name is memory, dignity, identity and self-worth.”
The Court acknowledged the critical role mothers play in shaping the emotional and social development of children and held that “it is the mother who gives birth to a child, therefore, she has every right to get her name on the academic testimonial of her children.” The Court noted the social progress since 2001 when it became mandatory to include the mother’s name in educational certificates and observed that the omission of the mother’s name or incorrect entries are retrogressive and unjustified in modern times.
The Court found merit in the petition and held that the rejection was solely on procedural grounds. The Court disposed of the petition with liberty to the petitioner to re-submit his application for name correction, this time complying with the procedural requirement of obtaining verification from the Headmaster/Principal of the concerned school.
The Court issued the following directions —
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Permitted the petitioner to file a fresh application along with an additional affidavit, duly verified by the Headmaster/Principal of the school from which he passed Class 10th and 12th.
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Upon receipt of the properly verified application, directed the Board to make the necessary corrections in the petitioner’s certificates and issue new mark sheets reflecting the correct name “Asha Naruka.”
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Directed to complete the entire exercise within three months from the date of receipt of a certified copy of the order.
[Chirag Naruka v. Board of Secondary Education, Rajasthan, S.B. Civil Writ Petition No.13360/2022, Decided on 15-05-2025]
Advocates who appeared in this case:
Mr. Rahul Sharma, Counsel for the Petitioner
Mr. Parth Vashishtha for Mr. Shantanu Sharma, Counsel for the Respondents
