Belated correction of a date-of-birth entry is barred by limitation and laches.

The petitioner sought correction of her date of birth in the Class X marksheet/certificate issued by the Chhattisgarh Board of Secondary Education.

She claimed that her actual date of birth was 27 August 2005, as reflected in her birth certificate and other documents, whereas the Class X records incorrectly recorded it as 28 August 2005.

She prayed for correction of the date of birth, issuance of a fresh corrected certificate, and corresponding changes in the respondents’ records and databases.

The Board opposed the petition on the ground that the claim had been raised after an inordinate and unexplained delay.

According to the applicable rules and procedure, correction of the date of birth could be sought only within three years from publication of the result.

The High Court considered the petition under Article 226 of the Constitution.

Whether the petitioner could seek correction of her date of birth in the Class X marksheet/certificate after the expiry of the prescribed three-year period and after considerable delay?

Whether the documents relied upon by the petitioner, including the birth certificate, entitled her to correction of the Board records at such a belated stage?

Whether the High Court should exercise its extraordinary jurisdiction under Article 226 of the Constitution in respect of the belated claim?

The Court applied the applicable rules and procedure governing correction of entries in the records of the Chhattisgarh Board of Secondary Education, under which correction of the date of birth was required to be sought within three years of publication of the result.

It further applied the principles of limitation, delay, and laches, holding that statutory procedures for correction of academic records cannot ordinarily be invoked after an inordinate delay to unsettle settled educational records.

The Court also relied on the discretionary and extraordinary nature of jurisdiction under Article 226 of the Constitution, which may be declined where the claim is stale or belated.

The Court accepted that the petitioner relied upon documents showing her date of birth as 27 August 2005, but held that the existence of such documents did not, by itself, overcome the prescribed limitation period for seeking correction in the Class X records.

Since the claim was brought after considerable and unexplained delay and outside the three-year period stipulated by the applicable Board rules, entertaining it would unsettle academic records at a belated stage.

Consequently, the Court declined to exercise its discretionary jurisdiction under Article 226 on the grounds of delay and limitation/laches.

The Court expressly clarified that it had not adjudicated the genuineness of the documents relied upon by the petitioner or the correctness of the date of birth claimed by her.