Authentic Public Documents Prevail Over Conflicting School Entries in CBSE Date-of-Birth Corrections

The petitioner sought correction of his date of birth in CBSE records from 15 November 2008 to 15 November 2007. He relied on a birth certificate issued by Patna Municipal Corporation on 3 December 2007 and a passport issued on 14 March 2008, both recording 15 November 2007. His Aadhaar card initially recorded 15 November 2008; after he obtained a correction from UIDAI, he applied to CBSE to correct its records. CBSE refused, relying on the school records, which also recorded 15 November 2008.

The petitioner challenged the Regional Officer’s rejection dated 17 July 2026 and sought correction of the CBSE certificates and consequential records.

CBSE argued that the school admission records reflected the date now appearing in its certificate and that the claim was an afterthought.

Whether CBSE should correct the petitioner’s date of birth in its records where contemporaneous public documents record a different date from the school and CBSE records.

Whether correction could be directed subject to the school first correcting its records.

The Court relied on Jigya Yadav (Minor) (Through Guardian/Father Hari Singh) v. Central Board of Secondary Education, (2021) 7 SCC 535, and the Patna High Court’s decision in Hamzah Hassan v. The Chairman, CBSE & Ors., CWJC No. 11145 of 2025, decided on 12 January 2026.

Applying the reasoning adopted in Hamzah Hassan, the Court treated authentic public documents, including a statutory birth certificate and passport, as capable of supporting correction of CBSE records; such documents prevail over a school-register entry unless controverted by other public documents or otherwise disproved.

The Court also referred to the Delhi High Court Division Bench decision in Central Board of Secondary Education v. Prema Evelyn D’Cruz & Anr., LPA 171/2023, concerning a person’s entitlement to accurate particulars in public documents.

The Court found substance in the petitioner’s reliance on the birth certificate and passport as public documents recording the claimed date of birth.

It followed its reasoning in Hamzah Hassan, under which such documents could prevail over a contrary school entry absent contrary public documents or proof disproving them.

The Court accordingly directed CBSE to process the correction after the school had properly corrected its records; it did not separately elaborate on the petitioner’s constitutional argument under Articles 19 and 21.

The Regional Officer was directed to process correction of the petitioner’s date of birth in the CBSE certificates from 15 November 2008 to 15 November 2007, after the school corrected its records, and to issue a fresh certificate within four weeks of receiving or being presented with the order, subject to payment of ₹5,000.

The Court noted that the petitioner was in Class XII and that the deadline for submission of the list of candidates was scheduled for 21 October 2026.