Chhattisgarh HC: a college can't refuse a genuine name-correction request just because no rule allows it
The Chhattisgarh High Court allowed a writ petition by a woman whose autonomous college had refused to correct her name and parentage in her degree and diploma certificates. The petitioner's school records showed her as "Surabhi Yadav, D/o Shiv Shankar Yadav"; after her 2012 marriage she studied and graduated under her married name, "Suhana Ansari". When the Family Court, Bilaspur, nullified the marriage in 2022, she sought restoration of her original identity in her academic records, pointing to her Aadhaar, caste certificate and a State Government notification that already recognised the change. The college's Governing Body rejected the request solely because no rule expressly permitted altering a certificate after results were declared.
Justice Amitendra Kishore Prasad held that absence of an enabling rule is not the same as a prohibition, and that an autonomous institution's academic autonomy does not place it beyond Article 226 judicial review for arbitrariness. Applying the Supreme Court's ruling in Jigya Yadav v. CBSE, (2021) 7 SCC 535, the Court held that where a person seeks correction consistent with public documents such as a court decree, Aadhaar card or Gazette notification, the authority must consider it, subject to reasonable safeguards like an affidavit, fee, public notice or Gazette publication, rather than refuse outright. The college was directed to process the correction within six weeks, without altering the course, marks or qualification already recorded.
Quick checkIn Surabhi Yadav v. Union of India, what did the Chhattisgarh High Court hold about an educational institution's refusal to correct a candidate's name where its rules are silent on the procedure?- Absence of an enabling provision is not the same as a prohibition, and a genuine request supported by public documents must be considered subject to reasonable safeguards
- The refusal is valid because academic certificates can never be altered after results are declared
- Silence in the rules amounts to an absolute prohibition, so the refusal was lawful
- The request could only be granted if the University, not the autonomous college, approved it
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Answer: A. The Court held that the Governing Body wrongly treated the absence of a specific rule as an absolute bar, when it should have examined the petitioner's documentary evidence and applied reasonable safeguards consistent with Jigya Yadav v. CBSE.
Issued by Chhattisgarh High Court. If this summary and the source differ, the source is right — tell us and we will correct it.
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