Under Section 15 of the Registration of Births and Deaths Act, 1969, the Registrar must conduct a due enquiry to determine if an entry is erroneous before rejecting a correction request, rather than dismissing it based on the extent of the name difference.

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO-

QUASH THE ENDORSEMENT ISSUED BY THE RESPONDENT BEARING NO. AA. VY/GBA(PA)/YAPU/PR/36/25-26 DATED 04.03.2026 PRODUCED VIDE ANNEXURE -E., AND ETC.

THIS PETITION, COMING ON FOR PRELIMINARY HEARING THROUGH VIDEO CONFERENCING / PHYSICAL HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE M.I.ARUN

ORAL ORDER

The petitioner approached the respondent seeking change the name of her grand-mother in the death certificate of her mother from "Mankamma to Mangamma". However, the same has been rejected on the ground that there has been a substantial difference in the name sought to be changed and the same is not permissible. Aggrieved by the same, the present writ petition is filed with a prayer to direct the respondent to change the name in the death certificate from "Mankamma to Mangamma" and also to set aside the impugned endorsement issued by the respondent, who states the same is not possible.

2. Section 15 of the Registration of Births and Deaths Act, 1969 reads as under:

"15. Correction or cancellation of entry in the register of births and deaths.—If it is proved to the satisfaction of the Registrar that any entry of a birth or death in any register kept by him under this Act is erroneous in form or substance, or has been fraudulently or improperly made, he may, subject to such rules as may be made by the State Government with respect to the conditions on which and the circumstances in which such entries may be corrected or cancelled, correct the error or cancel the entry by suitable entry in the margin, without any alteration of the original entry, and shall sign the marginal entry and add thereto the date of the correction or cancellation."

3. The said section empowers the jurisdictional Registrar to correct the name even if it is substantially different from what has been earlier entered in the death certificate. However, the same can be done after conducting a due enquiry and after the Registrar satisfying himself that there has been a genuine mistake in the name of the deceased entered in the death certificate.

4. Admittedly, no such enquiry has been conducted in the instant case and the impugned endorsement has been issued only on the ground that the name sought to be changed in the death certificate is completely different from what has been earlier entered. This in my opinion is erroneous.

5. Hence, the following:

ORDER

i. The Writ Petition is hereby disposed of.

ii. The impugned endorsement dated 04.03.2026 issued by the respondent vide Annexure-E to the writ petition is hereby set aside.

iii. The jurisdictional Registrar of Births and Deaths of the concerned Corporation coming under the Greater Bengaluru Authority is directed to conduct the necessary enquiry as contemplated under Section 15 of the Registration of Births and Deaths Act, 1969 and pass appropriate orders in accordance with law. The same shall be done within a period of one month from the date of receipt of a certified copy of this order.