Chhattisgarh High Court

Substitution of name in educational certificates due to post-marriage change is not a matter of right.

SMT SARITA CHANDRA vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: June 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner passed her High School Examination (2017) and Higher Secondary Examination (2022) conducted by the Chhattisgarh State Open School.

Source reference: para 2

Her name was recorded as "Sahodra Chandra" in the marksheet/certificates issued by the board.

Source reference: para 2

The petitioner married in 2005 and claims she has since used the name "Sarita Chandra" in other official documents like Aadhar and PAN cards.

Source reference: para 2

She executed a notarized affidavit and submitted a representation on 21.04.2026 to the respondents seeking a name change in her educational certificates to avoid difficulties in employment and banking.

Source reference: para 2-3
02

Issues

1. Whether the petitioner is entitled to a writ of mandamus directing the respondent Board to substitute her recorded name in educational certificates based on a post-marriage change of name.

Source reference: para 1, 8

2. Whether the lack of statutory provisions or evidence of clerical error precludes the court from granting the relief of name substitution.

Source reference: para 8-9
03

Law Applied

The court applied the principle of administrative law regarding the issuance of a writ of mandamus, which requires the existence of a legal or fundamental right and a corresponding mandatory statutory duty.

Source reference: para 9, 11

It further relied on the doctrine of finality in educational records, emphasizing that certificates reflect the particulars of a candidate as recorded at the time of admission and examination in accordance with the Board's specific rules and regulations.

Source reference: para 8, 10
04

Reasoning

The Court observed that this was not a case of clerical, typographical, or inadvertent error by the Board, but rather a request for the voluntary substitution of a name adopted after marriage.

Source reference: para 8

The Court noted that despite the petitioner marrying in 2005, she appeared for examinations in 2017 and 2022 as "Sahodra Chandra," failing to seek corrections during the admission or verification stages.

Source reference: para 10

The Court reasoned that educational certificates are intended to be historical records of the Board's data at the time of the exam.

Source reference: para 8

Crucially, the petitioner failed to cite any statutory provision, rule, or regulation that mandates the Board to alter or substitute a name after the results have attained finality.

Source reference: para 9-10

In the absence of a legal right or a statutory obligation on the part of the respondents, the court found no grounds to exercise its extraordinary writ jurisdiction.

Source reference: para 9, 11
05

Holding

The Court answered the issues in the negative and dismissed the writ petition.

It held that a petitioner cannot seek substitution of a name in educational records several years after the certificates were issued, especially when the name was correctly recorded based on the information provided at the time of examination and no statutory enabling provision for such a change exists.

Source reference: para 10-11

No order as to costs was made.

Source reference: para 11
Chhattisgarh High Court

Original Court PDF

SMT SARITA CHANDRAvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · June 24, 2026

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