Karnataka High Court Allows Minor To Change Name For Astrological Beliefs, Says Everyone Has Right To Be Recognized By Their Name

The Karnataka High Court has recently allowed an appeal filed by a minor girl seeking a declaration to change her name from 'Lakshmi N.'to 'Veena N.' in her school records due to numerological & astrological beliefs of her parents, holding that the right to be recognized by one's name is a civil right and that a civil suit for change of name is maintainable.[2026 LiveLaw (Kar) 404]

The single judge bench of Justice Hanchate Sanjeevkumar set aside the judgment and decree passed by a Bengaluru Civil Court which had dismissed the suit earlier.

“…Every person in society is necessarily to be recognized by his/her name. It is a civil right of every citizen in India to be recognized by his/her name. Therefore, for correction or change of name, filing a suit before the Civil Court is maintainable, as it relates to the adjudication of a civil right. Therefore, for change of the name of a candidate, the competent Civil Court has jurisdiction as per Section 9 of CPC…”, the court noted in the order.

The High Court specifically referred to a Circular issued on October 26, 2025 by the state government to the effect that if any person desires to change their name, the name of their parents, or date of birth, such candidate should obtain a decree from the competent Civil Court. Therefore, the parents had correctly filed the suit for declaration, the court opined.

“…It is a simple case of the plaintiff seeking declaratory relief for change of her name from “Lakshmi N.” to “Veena N..”… The Trial Court has simply dismissed the suit on the ground that the plaintiff has not produced any documents to show that her name is “Veena N.”. This reasoning of the Trial Court is unwarranted, as it is not the case of the plaintiff that, at the initial stage, while admitting the plaintiff to the school, her name was wrongly mentioned as “Lakshmi N.”. The plaintiff simply desires to be called as “Veena N.” and not “Lakshmi N. Therefore, there could not have been any occasion to produce any document showing the name of “Veena N.””, the court said in clear terms

The Court further noted that the Trial Court had assigned the reason that the parents had not approached the respondent authorities seeking change of name in school records. However, the Court held that the school did not have the authority to change the name in school or other records. The only recourse available to the plaintiff was to file a suit and obtain a decree from the competent Civil Court, the court opined

“…Therefore, when the suit is filed and evidence is given upon oath, unless the same is contrary to the evidence on record or otherwise disproved, the same can be accepted..”, the court concluded.

The Court noted that there was no objection by anybody else to changing the plaintiff's name, and the plaintiff had produced a public notice through newspaper publication intending to change her name.

To recap, the appellant/plaintiff, Lakshmi N., a minor represented by her natural guardian and father was born on October 10, 2010. During her naming ceremony, her parents named her as 'Lakshmi N'.

Subsequently, the parents desired to change her name to 'Veena N'. According to their astrological and numerological beliefs, the new name would bring more prosperity to the child, it was submitted.

Hence, the plaintiff filed a suit for declaration her name is 'Veena N', instead of "Lakshmi N.," and for a mandatory injunction directing the defendants to effect the new name in the school records and other public records.

The defendants in the suit were the State of Karnataka, the Deputy Director of Public Instructions, the Block Educational Officer, and the Head Master/Head Mistress of the child's schoo; who filed a written statement denying the plaintiff's case.

The Trial Court framed issues including whether the natural guardian had proved that his minor daughter's correct name is 'Veena N.' and not 'Lakshmi N'.

The Trial Court dismissed the suit on the grounds that the plaintiff had not produced any documents to prove that her name is 'Veena N.'. The court reasoned that public notices had not been issued publishing the change of name, and that the parents had not approached the first defendant school seeking change of name in the school records either

Adv Sampath Kumar AV for the appellant/plaintiff submitted that the parents had published a public notice in a daily newspaper intending to change the name of the plaintiff to Veena N. but the same was not produced before the Trial Court. The same was produced in the appeal by way of additional evidence by invoking the provisions under Order XLI Rule 27 of the CPC.

He further submitted that as per the Government Circular regarding change of name, a decree from the competent Civil Court is necessary, and therefore the plaintiff had filed the suit accordingly.

On the other hand, the Additional Government Advocate, submitted that the suit is not maintainable and prayed to dismiss the appeal, contending that the plaintiff had not produced any evidence to show that her name is Veena N.

Hence, the Court allowed the appeal and issued a mandatory injunction to the defendants to change the name of the plaintiff as 'Veena N.' in place of 'Lakshmi N.' in all the school records. The court, hence, also declared that the minor would hereafter be known as Veena N.