Educational authorities must correct clerical photograph errors after verifying original admission records.

The petitioner approached the Madhya Pradesh High Court under Article 226 of the Constitution seeking correction of an allegedly incorrect photograph appearing on his second-year Diploma in Elementary Education marksheets for the 2019–2020 session.

He claimed that he had submitted his correct photograph and had repeatedly requested the concerned authorities to rectify the error.

The correction was sought urgently because he had qualified for selection as a Primary School Teacher through the Rajasthan Staff Selection Board, with document verification commencing on 15 July 2026.

The respondent-Board opposed the petition on the ground of delay and relied upon Clause 4 of its instructions dated 14 January 2015, which prescribes the procedure and time limits for correction of photographs in marksheets.

The Board also relied on the decision in W.P. No. 17425 of 2022, affirmed in W.A. No. 1056 of 2022, concerning belated correction of date of birth.

The Court considered the principles stated in a coordinate Bench decision concerning correction of an erroneous photograph in academic records, where the error had arisen during online registration and the original institutional records established the petitioner’s identity.

Whether the petitioner’s delay in seeking correction of the photograph disentitled him from relief under Article 226 of the Constitution.

Whether the Board could be directed to correct the photograph in the petitioner’s second-year Diploma in Elementary Education marksheets when the alleged discrepancy resulted from an administrative or technical error and the petitioner’s identity was otherwise verifiable from original institutional records.

Whether the petitioner was entitled to immediate issuance of amended and corrected marksheets in view of the impending document-verification process.

The Court exercised its jurisdiction under Article 226 of the Constitution to address arbitrary or unreasonable administrative action affecting the petitioner’s academic records.

It considered Clause 4 of the Secondary Education Board’s instructions dated 14 January 2015, which provides for correction of a photograph on the basis of verified institutional records, attendance sheets, examination-application images and the photograph appearing on the admit card, subject to the prescribed procedural and temporal requirements.

The Court distinguished the principle in W.P. No. 17425 of 2022, affirmed in W.A. No. 1056 of 2022, that a belated application for correction of date of birth could not be entertained where the authority had no power to condone delay.

It relied on the coordinate Bench’s principle that a candidate should not suffer for a clerical or technical mistake in online registration where original institutional records establish identity and there is no finding of fraud, impersonation or malpractice; in such circumstances, the authorities must verify the original records and issue corrected academic documents.

The Court treated the present matter as one involving correction of an apparent photograph-related administrative error rather than a substantive alteration of the petitioner’s academic identity or qualifications.

In light of the coordinate Bench decision, the Court held that the issue could not be resolved merely by invoking delay where the petitioner’s identity could be verified from the original admission and institutional records and there was no allegation or finding of impersonation, fraud or malpractice.

The Board’s reliance on the date-of-birth correction case was therefore not determinative, since that case concerned a distinct statutory limitation and absence of authority to condone delay, whereas the present relief concerned rectification of a photograph in marksheets.

The urgency arising from the petitioner’s impending teacher-recruitment verification further justified expeditious directions for correction.

The petitioner was directed to apply before the Board within two working days.

Respondent No. 3 was directed to forward the original and relevant admission records to the Board within seven days and to provide copies to the petitioner and the Board within three working days.

The Court accordingly granted the requested corrective relief without separately awarding costs and disposed of the writ petition.