Chhattisgarh High Court
Immigration and Citizenship LawAdministrative and Public Law

Passport authorities must assess birth-date corrections against birth certificates and issue reasoned decisions.

DILRAJ SINHA vs UNION OF INDIA

Chhattisgarh High CourtJUDGMENT: October 12, 20262 MIN READSOURCE JUDGMENT
Passport authorities must assess birth-date corrections against birth certificates and issue reasoned decisions.. DILRAJ SINHA vs UNION OF INDIA. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner’s passport recorded his date of birth as 19 December 1999, whereas he claimed his correct date of birth was 19 December 2000, as shown in his birth certificate and Class 10 marksheet.

Source reference: para. 1–4

He sought re-issuance of the passport with the corrected date of birth, but the authorities returned or rejected his application with a remark that the date of birth did not match, without passing a reasoned order.

Source reference: para. 1–4

In the writ petition, the Union of India submitted that a fresh application supported by relevant public documents would be considered in accordance with law.

Source reference: para. 1–4
02

Issues

1. Whether the petitioner was entitled to a direction requiring the respondents to correct his date of birth in the passport to 19 December 2000

Source reference: para. 1, 6–7

2. Whether the competent authority should consider a fresh application for correction of the petitioner’s date of birth, having regard to his birth certificate

Source reference: para. 4, 7–8
03

Law Applied

The Court relied on Jigya Yadav (Minor) (Through Guardian/Father Hari Singh) v. Central Board of Secondary Education and Others, (2021) 7 SCC 535, as relevant to correction of date-of-birth records.

Source reference: para. 7

It also treated the petitioner’s birth certificate, recording his date of birth as 19 December 2000, as an undisputed public document relevant to the requested correction.

Source reference: para. 6

The Court did not identify a specific statutory provision; it directed that the competent authority consider the application in accordance with the applicable law and Ministry of External Affairs rules and guidelines.

Source reference: para. 4, 7–8
04

Reasoning

The Court noted that the birth certificate recorded 19 December 2000, while the passport showed 19 December 1999, and that the former date remained undisputed.

Source reference: para. 6

Rather than itself ordering the passport to be corrected, the Court gave the petitioner liberty to submit a fresh application and required the authorities to decide it in accordance with law, taking the birth certificate into account and applying the principles referred to in Jigya Yadav.

Source reference: para. 7
05

Holding

The Court disposed of the writ petition without directly ordering correction or re-issuance of the passport.

It directed that, upon filing a fresh application, the competent authority consider and decide it by a reasoned order within 60 days of receiving a certified copy of the order, keeping in view the date of birth recorded in the petitioner’s birth certificate.

Source reference: para. 7–9
Chhattisgarh High Court

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DILRAJ SINHAvsUNION OF INDIA

Chhattisgarh High Court · October 12, 2026

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