MP High Court Directs Correction Of Student's Date Of Birth In Class 10 Marksheet, Says Limitation Can't Defeat Legitimate Claim

The Madhya Pradesh High Court has allowed a writ petition seeking directions to the Madhyamik Shiksha Mandal to decide an application for correction of the petitioner's date of birth in her Class 10 marksheet, observing that the board, being a public authority, has a duty to ensure its records reflect true and correct particulars of a candidate. [2026 LiveLaw (MP) 233]

Rejecting the board's contention that the petition was barred by limitation, the court held that the petitioner was seeking correction of manifest error and not an alteration of the date of birth originally recorded in the school register. 

The bench of Justice Milind Ramesh Phadke observed:

"In the considered opinion of this Court, the respondent/Board has adopted an unduly technical approach. The limitation prescribed under the aforesaid Permanent Order cannot defeat a legitimate claim founded upon unimpeachable documentary evidence, particularly when the petitioner seeks correction of a manifest error and not alteration of the date of birth originally recorded in the school register. The object of maintaining educational records is to preserve accurate particulars of a student. The Board, being a public authority, is expected to ensure that its records reflect the true and correct particulars of the candidate". 

The petition was filed seeking directions against the Madhyamik Shiksha Mandal to expedite the disposal of the petitioner's application for correction of the birth date. The petitioner is seeking correction of her birth date as mentioned in the Class 10 mark sheet. 

Per the petitioner, her birthdate in the birth certificate was marked as August 22, 2007, but due to an inadvertent error, the birthdate in her class 10th marksheet was recorded as June 16, 2006. The petitioner also submitted the marksheet of class 8 and class 9 to support their claims.

The petitioner argued that after the discovery of this discrepancy, she approached the respondent/Board seeking correction of the birthdate, but the same was rejected, on the grounds that such applications can be considered only within a period of three years from the date of declaration of the examination result. 

The rejection stated that since the petitioner appeared in the High Court School Examination in 2022, and since the correction application was submitted beyond the prescribed period of three years, it was time-barred. 

The court noted that the issues relating to the entry of date of birth in the school register for the first time are governed under Madhya Pradesh Date of Birth (Entries in the School Register) Rules, 1973. Under Rule 3, the parent or guardian is required to declare the date of birth of the child at the time of first admission to a recognised school. Rule 4 further stipulates that the date of birth so declared shall be registered in the school register under the signature of the head of the Institute. 

The court further noted that Rules 7 and 8 pertain to the rectification of mistakes and correction or change in birthdate. Therefore, from a conjoined reading of the provisions, the court held that an application for correction cannot be entertained under Rules 7 and 8, after an examination form for the secondary level Board Examination has been forwarded to the Board or after the student has left the school. 

In the present case, the court noted that the present case did not involve a request for a change or alteration of the date of birth originally entered in school records. Rather, the present application seeks correction of an apparent clerical error that "crept into the Class X mark-sheet". 

Remarking that the board had adopted an "unduly technical approach" in rejecting the petitioner's application, the court observed that the limitation prescribed under the Permanent Order cannot defeat a legitimate claim founded upon unimpeachable documentary evidence, particularly when the petitioner seeks correction, not alteration, of the date of birth originally recorded in the school register. 

Thus, the bench allowed the writ petition and directed the board to consider the petitioner's application on merits and issue a fresh marksheet with the correct date of birth within six weeks. 

Case Title: Savitri v State of Madhya Pradesh, WP-47098-2025

Citation: 2026 LiveLaw (MP) 233

For Petitioner: Advocate Shankar Singh Tomar

For State: Advocate Smrati Sharma

For Man Ragistrar Mahodaya: Advocate Mayank Mishra

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