Clerical errors in online registration cannot justify denial of document correction absent proof of fraud or impersonation.

The petitioner was admitted to the GNM Course (session 2019-20) at respondent No. 2 college, submitting her correct photographs for the admission register.

Due to a technical error during online registration with the M.P. State Nurses Registration Council (Respondent No. 1), the photograph of another woman was uploaded.

Despite several communications from the college to the Council (dated 13.10.2021 and 26.08.2022) requesting rectification, the Council issued admit cards and marksheets for all three years with the incorrect photograph.

The petitioner was allowed to sit for all exams, passed successfully, but was unable to obtain professional registration due to the mismatch.

Following a High Court direction in a previous petition (W.P. No. 6753/2025), the Council issued an order dated 24.10.2025 rejecting her request for correction, citing delay and reliance on the data uploaded by the college.

1. Whether the rejection of the petitioner’s request for correction of a clerical/technical error in academic records by the Council was arbitrary and violative of Articles 14 and 21 of the Constitution.

2. Whether the lack of a specific statutory provision for correcting photographs precludes the Council from rectifying an undisputed clerical error.

The court applied the principles of administrative fairness and non-arbitrariness under Articles 14 and 21 of the Constitution of India.

The court relied on the doctrine that a party cannot be made to suffer for a clerical or technical mistake not attributable to them, especially when the state authority has accepted the candidate's identity by permitting them to appear in examinations and issuing results.

In the absence of an allegation of fraud or impersonation, the authorities are duty-bound to ensure official records reflect the truth.

The court found that the petitioner’s correct photograph was consistently present in the original institutional Admission Register and application forms, proving the error occurred during the online uploading process.

The Court rejected the respondents' plea of "delay and laches," noting the petitioner had continuously pursued the matter since the first-year admit card was issued and the respondents had failed to act on the college's repeated requests.

Critically, the Court observed that by allowing the petitioner to sit for exams over three years and evaluating her papers, the respondents had de facto accepted her identity.

Since no enquiry into impersonation or fraud was ever conducted or alleged, the Council’s refusal to correct a documented clerical error was deemed unreasonable and unsustainable.

The Court quashed the impugned order dated 24.10.2025 and directed the respondents to verify the petitioner’s identity using the original Admission Register and application forms and to issue corrected marksheets and consequential documents within six weeks.