Madhya Pradesh High Court

Passport authorities must consider name and date of birth corrections based on corrected statutory school records.

Satvik Singh Through Natural Legal Guardian Kamya Narvariya vs Union Of India

Madhya Pradesh High CourtJUDGMENT: March 31, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner sought a writ of mandamus to compel the Regional Passport Authority, Bhopal, to correct his name and date of birth in his passport records.

Source reference: para. 2

The petitioner’s previous passport, which expired on January 11, 2023, incorrectly recorded his name as "Satvik Narvariya" and his date of birth as "15.09.2008"

Source reference: para. 2

The petitioner contends that his correct name is "Satvik Singh" and his actual date of birth is "15.09.2010," as supported by his Class-X CBSE mark sheet, Aadhaar Card, and Samagra ID

Source reference: para. 1-2, 4

The automated passport system currently prevents the petitioner from applying for a fresh passport due to the discrepancy between his current application and the lapsed record

Source reference: para. 2
02

Issues

1. Whether the Regional Passport Authority can be directed to process a fresh passport application using corrected statutory documents regardless of incorrect entries in a previous, lapsed passport

Source reference: para. 1, 3

2. Whether the corrected Class-X mark sheet issued by CBSE constitutes a valid basis for the rectification of passport details under existing regulations

Source reference: para. 4
03

Law Applied

The court exercised its jurisdiction under Article 226 of the Constitution of India

Source reference: para. 1

Sub-clause (b)(ii) of Clause 2 of the Gazette Notification dated 24.02.2025, which identifies the Birth Certificate, School Leaving/Matriculation Certificate from a recognized board, and PAN card as prescribed documents for passport issuance

Source reference: para. 4

The court also invoked the equitable principle that human errors in documentation are rectifiable when justice so requires

Source reference: para. 8
04

Reasoning

The court examined the petitioner’s claim that the errors in the previous passport were due to inadvertence.

Source reference: para. 5

While the respondents argued that the petitioner should be held to the particulars originally furnished, the court noted that the petitioner now possesses a corrected Class-X mark sheet issued by the CBSE, which is a recognized statutory document for establishing identity and age.

Source reference: para. 4, 5

Rather than adjudicating the factual accuracy of the name and date of birth itself, the court focused on the petitioner's right to have his representation considered independently of the prior erroneous entries.

Source reference: para. 3

The court balanced the need for accuracy in official documents with the principle of "To err is human," concluding that the authority must evaluate the fresh evidence provided by the petitioner in accordance with the 2025 Gazette Notification.

Source reference: para. 8-11
05

Holding

The High Court disposed of the writ petition by directing the petitioner to submit a fresh representation to the competent authority within fifteen days, accompanied by necessary documents and affidavits.

The respondents were directed to consider and decide the representation in accordance with the law within three months.

Source reference: para. 11

The court held that the authority must process the application based on the statutory documents provided, without being unduly influenced by the previous incorrect entries.

Source reference: para. 3, 11

No order was made as to costs

Source reference: para. 12
Madhya Pradesh High Court

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Satvik Singh Through Natural Legal Guardian Kamya NarvariyavsUnion Of India

Madhya Pradesh High Court · March 31, 2026

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