Civil courts have jurisdiction to adjudicate claims seeking a change of personal name.

The appellant, a minor represented by her father and natural guardian, was named “Lakshmi N.” at birth. Her parents later wished to change her name to “Veena N.” for astrological and numerological reasons.

They sued for a declaration and mandatory injunction directing the authorities to change her name in the school and other records.

The trial court dismissed the suit, finding that no documents established the name “Veena N.,” no public notice had been produced, and the parents had not first sought the change from the school.

In the appeal, the appellant produced a newspaper public notice by an application under Order XLI Rule 27 CPC.

1. Whether the appellant had established sufficient grounds to change her name from “Lakshmi N.” to “Veena N.” in the school and other records

2. Whether the Civil Court had jurisdiction to hear a suit seeking a declaration for change of name

3. Whether the trial court’s judgment and decree warranted interference

Section 9 of the Code of Civil Procedure, 1908, confers jurisdiction on Civil Courts to try suits of a civil nature unless their jurisdiction is expressly or impliedly barred; the Court treated the right to be recognised by one’s name as a civil right capable of adjudication under that provision.

The Court also referred to Karnataka Government Circular No. ED 100 DTB 2014, dated 26 October 2025, which it understood to require a decree from a competent Civil Court for a change in a person’s name or related particulars.

The appellant relied on Order XLI Rule 27 CPC to place the newspaper public notice before the appellate court.

The Court found that the suit did not concern an erroneous original entry: the appellant’s parents had given her the name “Lakshmi N.” and later wished to change it to “Veena N.” Accordingly, the absence of earlier documents recording her as “Veena N.” did not defeat the claim.

The Court also rejected the trial court’s view that the parents first had to approach the school, reasoning that the cited Government Circular required a Civil Court decree for the change.

Considering the guardian’s sworn evidence, the newspaper notice produced on appeal, and the absence of any objection, the Court concluded that the requested change would cause no harm to the defendants or others.

It further held that a Civil Court could adjudicate the claim because it concerned a civil right.

It decreed the suit, declaring that the appellant was entitled to change her name from “Lakshmi N.” to “Veena N.” and directing the defendants to make that change in her school records.

It further declared that she was to be recognised as “Veena N.,” daughter of Ningegowda, for all consequential purposes. No costs were awarded.