In a significant ruling on date of birth correction in marksheet, the Madhya Pradesh High Court directed the Education Board to correct a student’s date of birth in the Class 10 marksheet. The Court again addressed date of birth correction in marksheet while clarifying that a clerical error cannot be rejected on technical limitation when records clearly show the correct date.
Background of the Petition
The petitioner approached the High Court under Article 226 of the Constitution. She asked the Court to correct her date of birth in the Class 10 marksheet from 16.06.2006 to 22.08.2007.
Justice Milind Ramesh Phadke heard the matter in Savitri v. State of Madhya Pradesh (W.P. No. 47098 of 2025) on 19 June 2026.
The petitioner stated that her birth certificate and earlier school records showed 22.08.2007 as her correct date of birth. However, the Class 10 marksheet recorded 16.06.2006 due to an error.
She submitted Class VIII and Class IX marksheets to support her claim. Both documents matched the birth certificate.
Application and Board Rejection
The petitioner applied to the Board on 01.07.2025 for correction of the error.
The Board rejected the request on 27.10.2025. It relied on its 2015 order. That order allowed correction requests only within three years of result declaration.
The Board argued that the request came after the limitation period. It therefore treated the application as time-barred.
Arguments Before the Court
The petitioner argued that she should not suffer due to a clerical mistake. She relied on Isha Mongia v. CBSE.
The Board defended its decision. It cited its 2015 policy and Babulal Singh v. State of M.P.. It argued that recorded dates cannot be changed later.
Court’s Analysis
The Court examined the Madhya Pradesh Date of Birth (Entries in School Register) Rules, 1973.
It noted that schools must record the date of birth at admission based on parental declaration. The head of the institution must sign the entry.
The Court also noted that rules restrict changes after the student progresses to higher examination stages. However, it drew a clear distinction between alteration and correction.
The Court found that the original school records, including admission records, Class VIII marksheet, and Class IX marksheet, all showed 22.08.2007.
Only the Class 10 marksheet showed 16.06.2006. The Court treated this as a clerical error.
Limitation Cannot Defeat Genuine Claim
The Court held that the Board wrongly relied on limitation. It found the approach overly technical.
It ruled that limitation cannot block correction when documents clearly prove the correct entry.
The Court stressed that public authorities must maintain accurate records. They must correct obvious mistakes when supported by strong evidence.
Final Order
The Court allowed the petition. It directed the Board to correct the date of birth and issue a fresh marksheet within six weeks.
The ruling reinforces that technical rules cannot override factual accuracy in cases of date of birth correction in marksheet.
