Madhya Pradesh High Court

Correction of Date of Birth in Service Records at the Fag End of Career is Impermissible.

Smt. Jalebiya Bai Panadiya v. The State of Madhya Pradesh and Others [2026:MPHC-JBP:19469]

Madhya Pradesh High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, Smt. Jalebiya Bai Panadiya, was appointed with a recorded date of birth of 01.04.1964 in her service record, leading to her scheduled superannuation on 31.03.2026

Source reference: para. 2

The petitioner claimed her correct date of birth is 01.04.1967 and alleged she only became aware of the discrepancy in 2025 upon receiving a list of employees due for retirement

Source reference: para. 2

She submitted a representation on 16.07.2025 seeking correction

Source reference: para. 2

The State opposed the petition, arguing that seeking a change in the date of birth at the "fag end" of a career is legally impermissible

Source reference: para. 3
02

Issues

1. Whether a government servant can seek the correction of their date of birth in service records at the fag end of their service career.

Source reference: para. 3-5
03

Law Applied

The court applied the principle that requests for changing the date of birth at the end of a service career are not sustainable, as established by the Supreme Court in Bharat Coking Coal Limited and Ors. v. Shyam Kishore Singh (2020) 3 SCC 411

Source reference: para. 3

This rule incorporates precedents such as State of Maharashtra v. Gorakhnath Sitaram Kamble and Home Deptt. v. R. Kirubakaran, which emphasize that such corrections disrupt seniority and promotion expectations of other employees

Source reference: para. 4

Furthermore, under State of M.P. v. Premlal Shrivas (2011) 9 SCC 664, even if evidence exists of an error, the correction cannot be claimed as a matter of right if there is an unexplained delay of several decades

Source reference: para. 4
04

Reasoning

The court found that the petitioner failed to provide any evidence of attempts to correct her date of birth during her entire service tenure until the eve of her retirement

Source reference: para. 4

Applying the Bharat Coking Coal Limited precedent, the court reasoned that the petitioner had "slept over her rights" for decades

Source reference: para. 4

The court noted that judicial interference at this late stage is discouraged because any change has a "chain reaction" affecting the promotion and seniority of other officers

Source reference: para. 4

Since the petitioner raised the dispute only months before her scheduled retirement in 2026, the court determined the request was hit by the doctrine of laches and was legally impermissible

Source reference: para. 5
05

Holding

The court answered the issue in the negative, holding that correction of the date of birth at the fag end of a career or after retirement cannot be acceded to

The High Court found no merit in the petition and dismissed it, thereby upholding the petitioner’s retirement date as 31.03.2026 based on the original service record

Source reference: para. 6
Madhya Pradesh High Court

Original Court PDF

Smt. Jalebiya Bai Panadiya v. The State of Madhya Pradesh and Others [2026:MPHC-JBP:19469]

Madhya Pradesh High Court · no citation

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment