The Madhya Pradesh High Court has held that a genuine clerical mistake in a student's educational record cannot be denied correction merely because the application was filed after the prescribed time limit. The Court directed the Madhya Pradesh Board to reconsider the student's request and issue a fresh Class 10 marksheet with the correct date of birth within six weeks.
Background of the Case
The petition was filed by Savitri, who sought correction of her date of birth in her Class 10 marksheet. According to her birth certificate and earlier school records, including Class 8 and Class 9 marksheets, her correct date of birth was 22 August 2007. However, her Class 10 marksheet mistakenly recorded it as 16 June 2006.
After noticing the error, she applied to the Madhya Pradesh Board for correction. The Board rejected the request, stating that its 14 January 2015 order permits date-of-birth corrections only if an application is made within three years of the examination result. Since Savitri had passed Class 10 in 2022 and applied in 2025, the Board treated the request as time-barred.
Justice Milind Ramesh Phadke examined the provisions of the Madhya Pradesh Date of Birth (Entries in the School Register) Rules, 1973. The Court noted that these rules generally restrict changes in the recorded date of birth after a student leaves school or after Board examination forms have been submitted. However, the Court found that Savitri's case was not one of changing her date of birth but correcting an obvious clerical mistake.
The Court observed that all available records created before the Class 10 marksheet including the birth certificate and earlier school marksheets consistently mentioned 22 August 2007 as the correct date of birth.
The bench observed,
"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 Court further remarked that educational authorities are expected to maintain accurate records and ensure that official documents correctly reflect a student's particulars.
Allowing the writ petition, the Madhya Pradesh High Court directed the Board to consider Savitri's application on its merits instead of rejecting it solely on the ground of delay.
The Court also instructed the Board to issue a fresh Class 10 marksheet carrying the correct date of birth within six weeks from the receipt of the certified copy of the order.
Case Details
Case Title: Savitri v. State of Madhya Pradesh & Others
Case Number: Writ Petition No. 47098 of 2025
Judge: Justice Milind Ramesh Phadke
Decision Date: 19 June 2026
