The High Court of Jammu & Kashmir and Ladakh at Jammu has come down strongly on the state education board for denying a young man’s request to change his name in school certificates. Justice Sanjay Dhar, delivering the verdict on September 11, 2025, ruled that the board’s refusal was 'not sustainable in law' and directed it to reconsider the application afresh.
Background
The petitioner, Mohd. Hassan, was originally named Raj Wali, a name that featured in all his educational certificates up to Class XII. In court, Hassan said he had long disliked the name, often becoming the subject of jokes among friends. As a child, he had no choice since his parents resisted changing it.
After completing graduation, he formally applied for a name change. The change was notified in the Gazette of India in April 2023, and his updated name was entered in Aadhaar, PAN, passport, voter ID, and even his domicile certificate. Armed with these documents, Hassan approached the Jammu and Kashmir Board of School Education (JKBOSE) to update his certificates.
But in December 2024, the board rejected his request, saying it was beyond its rules and also time- barred, since he had sought the correction more than three years after his matriculation.
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Court's Observations
Justice Dhar took a wider constitutional view, noting that the ''right to choose and change one’s name'' is part of the freedom of expression under Article 19(1)(a) and also connected to personal liberty under Article 21.
Quoting the Supreme Court’s ruling in Jigya Yadav vs. CBSE (2021), the bench remarked:
''Identity is an amalgam of various internal and external characteristics, and name is one of the foremost indicators of identity. An individual must be in complete control of her name.''
The judge rejected the board's stand that the three-year limit applied. ''That rule, ''he observed,
''relates only to correction of clerical or typographical errors, not to an acquired change of name supported by public documents.''
The court also noted precedents from Kerala, Delhi, and Allahabad High Courts, all holding that a bona fide request to change one's name cannot be brushed aside.
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Decision
Concluding the case, Justice Dhar quashed the board's December 2024 order. The court directed the JKBOSE to process Hassan's application afresh in light of the Supreme Court guidelines, considering his statutory documents.
If approved, the fresh certificates must record his name as ''Raj Wali alias Mohd. Hassan,'' ensuring consistency with both past records and his new identity.
With this, the court affirmed that choosing and asserting one’s name is a matter of personal dignity, not a bureaucratic privilege.
Case Title : Mohd. Hassan vs. Union Territory of J&K & Others
Case Number : WP(C) No. 21 of 2025
