IN THE HIGH COURT OF KERALA AT ERNAKULAM
ANIL K.NARENDRAN, MURALEE KRISHNA S., JJ.
State of Kerala, Represented By Its Secretary, Department Of General Education – Appellant
Versus
Sudhin Krishna C.S., (Previously Named Mohammed Riyazudeen C.S.), S/o. Syed Mohammed C.I. – Respondent
WA Nos.2780, 1631 & 2133 of 2025
Decided On : 17-03-2026
| Table of Content |
|---|
| 1. correction of name, caste and religion in s.s.l.c. (Para 1 , 2 , 3 , 4) |
| 2. judicial reliance on previous judgments and necessity for remand. (Para 5 , 6) |
| 3. arguments presented for and against corrections. (Para 7 , 8 , 9) |
| 4. importance of statutory provisions in decisions. (Para 10 , 11) |
JUDGMENT :
Muralee Krishna S., J.
[WA Nos.2780, 1631 & 2133 of 2025]
In all these writ appeals filed under Section 5 (i) of the Kerala High Court Act 1958 and in the writ petition filed under Article 226 of the Constitution of India, the issue involved is the correction pertaining to the change of name, caste and religion, as the case may be, in the Secondary School Leaving Certificate (‘S.S.L.C’ in short) of the respective writ petitioners, consequent to the Gazette notification about the same. For convenience, parties and documents are referred to in this judgment as in the respective writ petitions, unless otherwise stated.
2. W.A.No.1631 of 2025 is directed against the judgment dated 08.03.2021 passed by the learned Single Judge in W.P.(C)No.3832 of 2021, whereby the learned Single Judge allowed that writ petition, directing the 2nd respondent Joint Commissioner for Government Examinations, to correct the respective entries in the S.S.L.C. of the writ petitioner. In that writ petition, the petitioner sought a writ of mandamus commanding the Joint Commissioner for Government Examinations to correct the name, religion and caste of the petitioner in Ext.P1 S.S.L.C. of the petitioner in tune with Ext.P5 Gazette notification dated 08.12.2020 and also a writ of mandamus directing the State of Kerala to make necessary changes in the directions issued as per the Government Order dated 14.03.1984, considering the present change in situations.
3. W.A.No.2133 of 2025 is directed against the judgment dated 14.09.2023 in W.P.(C)No.18243 of 2023, whereby the learned Single Judge allowed that writ petition, directing the 2nd respondent Joint Commissioner, to correct the respective entries in the S.S.L.C. of the writ petitioners concerned. The petitioners in that writ petition sought a writ of mandamus commanding the Headmaster of the Kelappan Memorial Government Vocational Higher Secondary School, Tavanur, who is the 3rd respondent in that writ petition, to correct the caste of the petitioners in the school records based on Exts.P4 and P5 community certificates and consequently issued appropriate directions to the Joint Commissioner to accept Exts.P6 and P8 applications dated 29.07.2019, seeking correction of caste in Exts.P2 and P3 S.S.L.C of the respective petitioners and effect necessary corrections to the caste therein as Hindu Ezhava, OBC, within a time frame to be fixed by this Court and also to quash Ext.P7 endorsement dated16.03.2020 made by the Joint Commissioner.
4. W.A.No.2780 of 2025 is directed against the judgment dated 26.05.2025 in W.P.(C)No.41609 of 2024, whereby the learned Single Judge allowed that writ petition, directing the appellants to correct the respective entries in the S.S.L.C. of the writ petitioner. The said writ petition was filed by the petitioner therein seeking a writ of certiorari to quash Ext.P5 note attached to the application of the petitioner, made at the time of returning the application as defective on 19.08.2024, by the Joint Commissioner of Examinations; a writ of mandamus commanding the 2nd respondent Joint Commissioner of Examinations to accept Ext.P1 application dated 06.06.2024 submitted by the petitioner before the District Educational Officer and allow the same within a period that would be fixed by this Court.
5. In W.P.(C)No.18243 of 2023, the Joint Commissioner filed a counter affidavit dated 26.07.2023, producing therewith Exts.R2(a) and R2(b) documents.
6. By the judgment dated 08.03.2021, the learned Single Judge allowed W.P.(C)No.3832 of 2021 as mentioned above. It is relying on the said judgment, W.P.(C)No.18243 of 2023 was allowed by the learned Single Judge as per the judgment dated14.09.
The court holds that failure to challenge relevant government orders impacts the proceedings regarding corrections in school records.
Respondents are under obligation to maintain correct records and in this regard make corrections as and when detected or brought into their notice.
Administrative law dictates that name changes on official documents require adherence to established protocols; clerical errors may be corrected, but substantive changes must follow due process.
Name changes in educational certificates require adherence to reasonable procedures, allowing corrections based on legal identity documents without excessive restrictions.
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