Karnataka High CourtAdministrative and Public LawCivil Law

Karnataka HC Orders BBMP to Change Deceased Woman’s Death Certificate From ‘Padma’ to ‘Swarnam’ After Civil Court Declaration

SRI. RAMAKRISHNANv.THE STATE OF KARNATAKA

Karnataka HC Orders BBMP to Change Deceased Woman’s Death Certificate From ‘Padma’ to ‘Swarnam’ After Civil Court Declaration. SRI. RAMAKRISHNAN vs THE STATE OF KARNATAKA. Karnataka High Court. LawLens
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In brief

The question

Whether the second respondent could reject the request to correct the death-register entry despite the civil court’s declaration that the deceased’s name was “Swarnam” and not “Padma”

The court held

The Court allowed the petition and quashed the second respondent’s endorsement dated 19 May 2026.

It also directed

The petitioner was permitted to submit a certified copy of the High Court order within two weeks of receiving it, and the second respondent was directed to correct the death register and issue a fresh death certificate recording the deceased’s name as “Swarnam” within six weeks of receipt.

01Facts

The petitioner sought to correct the deceased wife of S. Padmanabhan’s name in the death register from “Padma” to “Swarnam.”

pp. 2–6

After an earlier writ petition directed consideration of his representation, the petitioner brought O.S. No. 3914/2025. The civil court declared that her name was “Swarnam” and not “Padma,” dismissed the claim for mandatory injunction, and granted liberty to seek correction from the competent authority in accordance with specified High Court decisions.

pp. 2–6

The second respondent nevertheless rejected the petitioner’s subsequent request, stating that the correction was beyond its powers under Section 15 of the Registration of Births and Deaths Act, 1969. The petitioner challenged that endorsement in this writ petition.

pp. 2–6

02Issues

i.Whether the second respondent could reject the request to correct the death-register entry despite the civil court’s declaration that the deceased’s name was “Swarnam” and not “Padma”

pp. 5–8

ii.Whether the second respondent could reject the request without following the procedure contemplated under Rule 11 of the Karnataka Registration of Births and Deaths Rules, 1999

p. 8

03Law Applied

Section 15 of the Registration of Births and Deaths Act, 1969 empowers correction of an entry in the register where it is erroneous in form or substance, or was made fraudulently; Rule 11 of the Karnataka Registration of Births and Deaths Rules, 1999 prescribes the procedure for examining such correction requests.

p. 7

The Court also referred to W.P. No. 38423/2018 and W.P. No. 18803/2024, which the civil court had relied on for the proposition that a Registrar’s power under Section 15 extends to replacing a name in the relevant record.

pp. 6–7

Provisions in the judgment · 2 · Linked ones open on LawLens

Registration of Births and Deaths Act, 1969 Section 15

Code of Civil Procedure, 1908 Section 9

04Reasoning

The civil court, after contest and with the Chief Registrar represented, had declared that the deceased’s name was “Swarnam” and not “Padma,” while leaving the petitioner to approach the competent authority for correction.

pp. 5–7

The second respondent could not disregard that decree and reject the request on jurisdictional grounds without extending the opportunity inherent in the Rule 11 procedure.

p. 8

Given the declaration and the liberty granted by the civil court, the Court considered a further enquiry an empty formality and directed the correction.

p. 8

The correction was confined to the death-register entry and would not determine any issue concerning the petitioner’s asserted legacy.

pp. 8–9

05Holding

The Court allowed the petition and quashed the second respondent’s endorsement dated 19 May 2026.

p. 9

The petitioner was permitted to submit a certified copy of the High Court order within two weeks of receiving it, and the second respondent was directed to correct the death register and issue a fresh death certificate recording the deceased’s name as “Swarnam” within six weeks of receipt.

p. 9
Karnataka High Court

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SRI. RAMAKRISHNANvsTHE STATE OF KARNATAKA

Karnataka High Court · September 24, 2026

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