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2026 Supreme(Guj) 891

xIN THE HIGH COURT OF GUJARAT AT AHMEDABAD
NIRZAR S. DESAI, J.
Parghi Kishan Harjibhai – Petitioner 
Versus
State Of Gujarat And Ors. – Respondents 
SPECIAL CIVIL APPLICATION NO. 17625 of 2025
Decided On :  20-04-2026

Advocates Appeared:
For the Petitioner: Umang P Raval
For the Respondent: Ms Kinjal Vyas Assistant Government Pleader, Mr Meet Shah For Mr Ad Oza

Educational authorities are legally obligated to rectify errors in school records, such as caste entries, when supported by authentic statutory documentation. Procedural regulations prohibiting such amendments after a student leaves an institution cannot be used to deny legitimate corrections, as such refusal constitutes an arbitrary exercise of power.

Headnote:(A) Education Law - Correction of entries in school certificates - Whether educational authorities can decline the correction of caste entries on the ground that the student has left the institution - Statutory certificates like caste and birth certificates possess high evidentiary value - Regulatory restrictions on post-school amendments cannot be invoked to defeat a genuine claim of correction. (Paras 7, 14, 16)

(B) Writ Jurisdiction - Exercise of extraordinary powers under Article 226 - When state authorities fail to exercise their duty to rectify obvious errors based on authentic statutory records, the court may invoke its extraordinary jurisdiction to direct the necessary corrections despite arguments of alternative remedies. (Paras 10, 14, 16)

Facts of the case:
The petitioner sought to update his caste entry in his school leaving certificate to accurately reflect his social category. The educational authority rejected the request, relying on procedural regulations that prohibit the alteration of records after a student has left the institution. The petitioner challenged this rejection, contending that his actual status was supported by multiple valid, government-issued certificates, and that failure to act amounted to an arbitrary exercise of authority.

Findings of Court:
The court determined that procedural rules cannot override the duty of educational authorities to maintain accurate records when supported by high-probative statutory evidence. The court emphasized that the refusal to rectify errors, despite the submission of valid government documentation, is arbitrary and violates the public duty to maintain correct official records.

Issues: Whether educational authorities can justify denying the correction of caste details in a school leaving certificate solely based on procedural regulations, notwithstanding the presentation of authentic and statutory supporting documents.

Ratio Decidendi: Authorities are obligated to verify and correct errors in school records when provided with credible statutory documentation. A policy that blindly prohibits record amendments after a student departs is untenable when it results in the perpetuation of incorrect information, especially when such corrections are supported by government-issued evidence.

Result: Petition allowed; the impugned order of rejection was set aside with directions to the authorities to verify the documents and issue a corrected certificate.

Table of Content
1. petitioner seeks correction of caste record based on official government documentation. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8)
2. conflict between administrative record closure rules and evidence-based correction requests. (Para 9 , 10 , 11 , 12 , 13)
3. statutory certificates represent high evidentiary value, overriding procedural barriers to correction. (Para 14 , 15)
4. mandatory correction of erroneous public records is a non-discretionary duty of administrative authorities. (Para 16 , 17)

JUDGMENT :

NIRZAR S. DESAI, J.

1. Heard learned advocate Mr. Umang Raval appearing for the petitioner, learned advocate Mr. Meet Shah appearing for learned advocate Mr. A. D. Oza for respondent Nos. 1 and 4 and learned Assistant Government Pleader Ms. Kinjal Vyas appearing for respondent No. 2 – State.

2. Despite service of notice, respondent No. 3 has chosen not to appear before the Court.

3. By way of this petition, the petitioner seeks correction of the caste mentioned from 'Hindu Chamar' to 'Hindu Vankar' in his School Leaving Certificate, changing it , and further seeks a direction to Respondent No. 3 to issue a new School Leaving Certificate reflecting his correct caste as 'Hindu Vankar'.

4. With the consent of learned advocates appearing for the respective parties, the matter was taken up for final hearing. Hence, RULE. Learned Assistant Government Pleader Ms. Kinjal Vyas waives service of rule on behalf of Respondent No.2, and learned advocate Mr. Meet Shah, for learned advocate Mr. A. D. Oza, waives service of rule on behalf of Respondent Nos. 1 and 4.

5. It is the case of the petitioner that he completed Standard 10 from Respondent No. 3 school, i.e., Government High School, Botad, on 07.06.2012, and at that time, the school authorities issued a School Leaving Certificate, being Certificate No. 243, wherein, in the column of religion and caste, the petitioner’s religion and caste were shown as “Hindu Chamar.”

6. It is the case of the petitioner that his true religion and caste are “Hindu Vankar.” This is supported by certificates, including a caste certificate issued by the Mamlatdar, Botad, on 27.12.2010, stating that the petitioner belongs to the “Hindu Vankar” caste, which falls under the Scheduled Caste category, and another certificate issued by the Mamlatdar, Botad, on 16.12.2011, also indicating that the petitioner’s religion and caste are “Hindu Vankar,” belonging to the Scheduled Caste category.

7. When the petitioner made an application to the District Education Officer, Botad, for the necessary correction of his caste, Respondent No. 2—i.e., the District Education Officer, Botad—rejected the petitioner’s application vide order dated 16.10.2025 on the ground that, once the petitioner had left the school, the school record could not be altered as per Regulations No. 12A(5)(6), and therefore the requested correction could not be made.

8. Therefore, the petitioner has challenged the aforesaid order dated 16.10.2025 with the prayer stated hereinabove.

9. Learned advocate Mr. Umang Raval submitted that the concerned District Education Officer has ample power to make the necessary correction relating to caste in the School Leaving Certificate by issuing appropriate directions to the school; however, such powers were not exercised by the concerned District Education Officer.

10. Learned advocate Mr. Umang Raval relied upon a decision of this Court dated 11.07.2022 in Special Civil Application No. 18550 of 2021, in the case of Ashifbhai Aminbhai Bhayani versus State of Gujarat, and submitted that in a similar situation, when the petitioner of that petition approached this Court for making necessary corrections in respect of his caste as well as name, the Co-ordinate Bench of this Court, after considering Rule 12A(6) of the Gujarat Secondary and Higher Secondary Education Regulations , had issued necessary directions to the concerned respondent while allowing the petition. Therefore, this Court may pass a similar order in re

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