Gujarat High CourtAdministrative and Public LawEducation Law

School records can be corrected even after a student leaves school if existing entries are erroneous.

PARGHI KISHAN HARJIBHAIv.STATE OF GUJARAT

School records can be corrected even after a student leaves school if existing entries are erroneous.. PARGHI KISHAN HARJIBHAI vs STATE OF GUJARAT. Gujarat High Court. LawLens
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In brief

The question

1. Whether the District Education Officer has the authority to direct the correction of caste in a School Leaving Certificate after the student has left the school, notwithstanding the restrictive provisions of Regulation 12A

The court held

The Court allowed the petition and quashed the DEO's order dated October 16, 2025. It held that the restrictions under Rule 12A(5)(6) do not preclude the Court or the DEO from correcting a genuine error in caste

It also directed

The Court directed the petitioner to submit a fresh application to the DEO with supporting family documents. It further directed the DEO to verify the genuineness of these documents and, upon satisfaction, instruct Respondent No. 3 to issue a fresh SLC reflecting the caste as "Hindu Vankar" within three months

01Facts

The petitioner completed Standard 10 at Government High School, Botad (Respondent No. 3) in 2012. His School Leaving Certificate (SLC) recorded his caste as "Hindu Chamar"

¶ 5

The petitioner asserted his correct caste is "Hindu Vankar," supported by caste certificates issued by the Mamlatdar in 2010 and 2011

¶ 6

He applied to the District Education Officer (DEO), Botad (Respondent No. 2), for correction, but the application was rejected on October 16, 2025. The DEO cited Regulations 12A(5)(6) of the Gujarat Secondary and Higher Secondary Education Regulations, stating that school records cannot be altered once a student has left the institution

¶ 7

The petitioner subsequently challenged this rejection before the High Court

¶ 8

02Issues

i.1. Whether the District Education Officer has the authority to direct the correction of caste in a School Leaving Certificate after the student has left the school, notwithstanding the restrictive provisions of Regulation 12A

¶ 9, 14

ii.2. Whether the refusal to correct a documented error in school records based on procedural technicalities constitutes an arbitrary exercise of power

¶ 14 (referencing precedent)

03Law Applied

The Court primarily interpreted Regulation 12A(5) and (6) of the Gujarat Secondary and Higher Secondary Education Regulations, which generally restricts amendments to school records after a student departs

¶ 7, 10

The Court relied on the legal principle established in Ashifbhai Aminbhai Bhayani v. State of Gujarat (SCA No. 18550 of 2021) and previous Division Bench rulings, which hold that errors in statutory documents must be corrected to prevent arbitrary injury to a citizen. These precedents establish that the DEO possesses the inherent power to issue directions for such corrections when supported by high-evidentiary value documents, such as statutory certificates issued by a Mamlatdar or Registrar

¶ 10, 14, 15

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

Registration of Births and Deaths Act, 1969 Section 12Section 17

04Reasoning

The Court observed that while the respondent authorities relied on the restrictive language of Rule 12A to deny the correction, judicial precedents have consistently held that authorities are not "error-proof" and total denial of correction amounts to a violation of public duty

¶ 14

The Court noted that the petitioner provided credible evidence, including his own caste certificates and those of his real brother, showing the "Hindu Vankar" status

¶ 6, 13

Applying the reasoning from the Ashifbhai case, the Court found that a resident should not be forced to "run from pillar to post" for a genuine correction when there is no dispute regarding the authenticity of the supporting statutory certificates

¶ 14

The High Court determined that the DEO failed to exercise their jurisdiction to verify the documents and provide relief, rendering the rejection order unsustainable

¶ 16

05Holding

The Court allowed the petition and quashed the DEO's order dated October 16, 2025. It held that the restrictions under Rule 12A(5)(6) do not preclude the Court or the DEO from correcting a genuine error in caste

¶ 16, 17

The Court directed the petitioner to submit a fresh application to the DEO with supporting family documents. It further directed the DEO to verify the genuineness of these documents and, upon satisfaction, instruct Respondent No. 3 to issue a fresh SLC reflecting the caste as "Hindu Vankar" within three months

¶ 16, 17
Gujarat High Court

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PARGHI KISHAN HARJIBHAIvsSTATE OF GUJARAT

Gujarat High Court · April 20, 2026

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