Patna High Court
Administrative and Public LawEducation Law

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

Ahad Rayees vs The Central Board of Secondary Education

Patna High CourtJUDGMENT: October 13, 20262 MIN READSOURCE JUDGMENT
Authentic Public Records Prevail Over School Entries in CBSE Date-of-Birth Corrections. Ahad Rayees vs The Central Board of Secondary Education. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner sought correction of his date of birth in his CBSE Class X marks statement and certificate from 04.03.2005 to 04.05.2004.

Source reference: pp. 1–6

He relied on a hospital-issued birth certificate, a municipal birth registration, and his passport, all said to record 04.05.2004.

Source reference: pp. 1–6

He stated that a later municipal certificate recording 04.03.2005 had been obtained on incorrect advice and was cancelled in January 2025.

Source reference: pp. 1–6

CBSE rejected the correction request, relying on the date of birth recorded at school admission and in the list of candidates submitted for the examination.

Source reference: pp. 1–6

The petitioner challenged that rejection under Article 226 of the Constitution.

Source reference: pp. 1–6
02

Issues

Whether CBSE was required to process correction of the petitioner’s date of birth on the basis of the public documents relied upon, notwithstanding the school and examination records recording a different date.

Source reference: paras 9–13; pp. 4–9

Whether the petitioner was entitled to a direction quashing the rejection and requiring issuance of a corrected certificate.

Source reference: paras 2–3, 13; pp. 1, 9
03

Law Applied

Article 226 of the Constitution empowers the High Court to grant appropriate relief where a public authority’s decision warrants judicial intervention.

Source reference: paras 11–12; pp. 6–9

Relying on Jigya Yadav (Minor) (Through Guardian/Father Hari Singh) v. Central Board of Secondary Education, (2021) 7 SCC 535, the Court stated that CBSE is obliged to carry out corrections in its certificates where public records having statutory presumptions of genuineness have been corrected or altered.

Source reference: paras 11–12; pp. 6–9

It also followed Hamzah Hassan v. Chairman, Central Board of Secondary Education & Ors., CWJC No. 11145 of 2025, decided 12 January 2026, which held that relevant public documents may prevail over school-register entries unless controverted by other public documents or otherwise disproved; that decision, in turn, relied on Central Board of Secondary Education v. Prema Evelyn D’Cruz & Anr., LPA 171/2023.

Source reference: paras 11–12; pp. 6–9
04

Reasoning

The Court found substance in the petitioner’s reliance on public documents recording 04.05.2004 and applied the principle in Jigya Yadav and Hamzah Hassan that such documents can support correction of a CBSE certificate despite a contrary school entry.

Source reference: paras 11–14; pp. 6–9

It therefore directed CBSE to process the application after the date of birth was properly corrected by the school.

Source reference: paras 11–14; pp. 6–9

The Court also took account of what it described as the petitioner’s parents’ admitted mistake or unfair approach when imposing costs.

Source reference: paras 11–14; pp. 6–9
05

Holding

The writ petition was allowed.

CBSE was directed to process the correction through the school and issue a fresh certificate changing the date of birth from 04.03.2005 to 04.05.2004 within six weeks of receiving or being supplied a copy of the order.

Source reference: paras 13–15; pp. 9–10

The petitioner was also directed to deposit costs of ₹15,000 by demand draft in favour of the Secretary, CBSE, within four weeks.

Source reference: paras 13–15; pp. 9–10
Patna High Court

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Ahad RayeesvsThe Central Board of Secondary Education

Patna High Court · October 13, 2026

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