Passport authority must correct spouse’s name and renew passport upon production of sufficient documentary proof.

The petitioner obtained a passport in 1994 where his wife’s name was recorded as ‘Jayshben Vishnukumar Chauhan’

In 2021, while applying for renewal, the petitioner sought to correct the spouse’s name to her actual name, ‘Niruben Vishnukumar Chauhan’

Despite submitting an affidavit and relevant documents, the respondent authority closed the application in 2023 without action

The petitioner filed a fresh application in 2024, providing a Marriage Certificate, Government Gazette, and identity proofs

A subsequent police inquiry by Vadaj Police Station verified these documents and submitted a favorable report to the respondent

However, the respondent remained reluctant to reissue the passport, prompting the petitioner to seek relief under Article 226 of the Constitution due to an urgent need to travel to London for his daughter-in-law's pregnancy

1. Whether the respondent Passport Authority was justified in its inaction regarding the renewal and correction of the petitioner’s passport despite the submission of comprehensive documentary evidence and a favorable police verification report?

The Court exercised its writ jurisdiction under Article 226 of the Constitution of India

The matter is governed by the principles of administrative fairness and the statutory obligations of the Passport Authority to process renewals and corrections when presented with authentic proof of identity, such as the Government Gazette, Marriage Certificate, and police verification reports

The Court observed that the petitioner, a person of limited education, had committed an inadvertent error regarding his spouse's name during the initial 1994 application

The Court noted that the petitioner had subsequently produced all "relevant and necessary documents," including the Aadhar Card, PAN Card, Election Card, Newspaper advertisement, and Name Change Gazette

Critically, the Court found that the respondent's own verification process via the Vadaj Police Station had confirmed the accuracy of the name 'Niruben Vishnukumar Chauhan'

The Court reasoned that once the respondent authority was in possession of these documents and a confirming police report, it "ought to have renewed and reissued the passport" with the requested changes rather than closing the application

It held that the respondent’s inaction was unjustified given the weight of the evidence provided.

The Court directed the respondent Passport Authority to change the spouse’s name from ‘JAYSHBEN VISHNUKUMAR CHAUHAN’ to ‘NIRUBEN VISHNUKUMAR CHAUHAN’ and to renew and reissue the petitioner's passport accordingly

No order as to costs was made