After Her Marriage Was Nullified, Chhattisgarh HC Directs College To Restore Graduate’s Original Name In Academic Records, Subject To Verification

The petitioner’s pre-marriage school records identified her as “Surabhi Yadav, D/o Shiv Shankar Yadav.”

After marrying in 2012, she pursued courses at an autonomous college under the name “Suhana Ansari”; her academic documents included inconsistent particulars, including an erroneous description of her husband as her father on a diploma certificate.

Following a Family Court decree nullifying the marriage on 24 February 2022, she resumed her original name and sought corresponding changes to her academic records.

After her representation was referred to the college, its Governing Body rejected the request on 6 March 2023, principally because no applicable rule expressly permitted the alteration.

The petitioner challenged that resolution under Article 226.

In Jigya Yadav (Minor) through Guardian/Father Hari Singh Yadav v. Central Board of Secondary Education, (2021) 7 SCC 535, the Supreme Court distinguished correction of particulars from a change of name and held that a request to align an educational certificate with authentic public documents may be considered subject to reasonable safeguards, such as an affidavit, prescribed fee, Gazette publication or public notice, surrender of the original certificate, and an appropriate annotation.

The Court also relied on the principle that a person’s name is an element of identity protected by the freedom of expression under Article 19(1)(a).

Under Article 226, an autonomous institution’s decision remains reviewable for legal error, arbitrariness, or failure to act fairly; institutional autonomy does not confer immunity from judicial review.

The petitioner’s request was supported by a documented chain of identity: her pre-marriage educational records, the post-marriage name used during her studies, the Family Court decree, and subsequent public and governmental records.

Although the college could verify the documents and impose reasonable safeguards, the absence of an express procedural rule did not amount to a substantive prohibition.

By treating that absence as an absolute bar, the Governing Body failed to apply the standard in Jigya Yadav and did not adequately address the documentary evidence or inconsistencies in its own records.

The alternative-remedy objection was rejected because the petitioner challenged a specific final decision and the respondents had not shown that the UGC mechanism was efficacious for the relief sought in these circumstances.

It directed the college to process the petitioner’s request for restoration of her name in her academic records, subject to reasonable verification and safeguards, and to issue corrected documents or an appropriate endorsement identifying her as “Surabhi Yadav D/o Shiv Shankar Yadav, Mother Sulekha Yadav.”

The correction must not alter her academic particulars; the University must provide consequential cooperation, and the exercise is to be completed preferably within six weeks of receipt of the certified order.

The Court declined to order reconsideration of the college’s recognition, disciplinary proceedings, or compensation, and made no order as to costs.