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Courts Cannot Direct Education Boards to Alter Date of Birth in School Records:
In a significant ruling regarding the limits of in administrative matters, the has clarified that courts do not possess the mandate to direct educational boards to unilaterally alter a candidate's date of birth in school records. The decision, delivered by a Division Bench, emphasizes that such requests must first be addressed through the controlled by the respective boards.
Background of the Dispute The matter reached the via a filed by the , Rajasthan . The appellant challenged a lower court's directive that had ordered the Board to modify a student's date of birth in her Class Xth certificate. The Board argued that the single judge had erroneously relied on previous, potentially misplaced, judicial precedents in issuing the order without allowing the administrative process to run its course.
The Legal Question At the heart of the litigation was whether the judiciary could exercise its to bypass the established administrative procedures of educational boards when a student seeks a correction of their personal data in academic certificates.
Arguments Presented The contended that the correction of a date of birth is a matter that must be examined at the initial level by the Board itself. Relying on the Supreme Court judgment in , the appellant argued that the authority to verify documents and confirm factual accuracy lies with the Board. If the Board declines to make the requested change, the aggrieved individual must then seek recourse through the regular system rather than asking the High Court to act as a recording agency.
The Respondent acknowledged the legal landscape and, in a shift from the original petition, requested that the Court permit her to submit supporting documentation to the Board directly, praying for the Board to consider and adjudicate upon the request in a timely manner.
Judicial Reasoning and Precedents The Division Bench of the High Court, comprising Acting Chief Justice Sanjeev Prakash Sharma and Justice Maneesh Sharma, agreed with the appellant. Referring to the Supreme Court's guidance in Jigya Yadav , the bench observed:
"We are in agreement with the counsel for appellant and hold that this Court would not be authorized for change the date of birth, accordingly, the judgment passed by learned Single Judge, wherein directions were issued to change the date of birth is set aside."
The Court emphasized a structured approach: primary evidence must be reviewed by the administrative body. If that body denies the request, a "" must be provided by the Board, offering the applicant the necessary grounds to challenge the decision in an appropriate .
Key Observations The judgment clarifies the judicial stance on the correction of academic records:
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"We are in agreement with the counsel for appellant and hold that this Court would not be authorized for change the date of birth."
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The Court noted that the Board is required to
"examine the documents of the candidate and if it is found that necessary change in date of birth is required, the same may be made as per their own decision."
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The Board is enjoined to provide clarity, stating,
"If, however, they reach to a conclusion that the date of birth is not required to be changed, they shall pass a ."
Final Decision The allowed the appeal in part, setting aside the single judge's directive. The court ordered that the respondent must submit her documents to the Board, which is now mandated to examine the application on its merits. Should the Board reject the application, it must issue a reasoned order, effectively providing a roadmap for the student to approach a to prove the veracity of her claim. This ruling reaffirms the principle of before seeking in academic record-keeping.
