In a major constitutional ruling, the Kerala High Court has reinforced an individual’s right to freely choose and reflect their religious identity in official documents. Justice D.K. Singh, while hearing the case of Sudhin Krishna C.S. v. State of Kerala & Others (WP(C) No. 41609/2024), upheld the petitioner’s plea to change his religion and name in the SSLC certificate after lawful conversion from Islam to Hinduism.
The petitioner, originally named Mohammed Riyazudeen C.S., was registered under the Islamic faith by his father during school admission. However, brought up by his Hindu mother and married to a Hindu woman, he later converted to Hinduism as an adult and officially notified the change via a gazette and a certificate from Arya Samaj.
Despite submitting all necessary documents, including proof of conversion, his request to update school records was rejected on the grounds that the Kerala Education Rules (KER), 1959, do not explicitly permit such changes. The authorities argued that no competent officer had been designated for religion or name correction.
Justice Singh rejected this contention, clarifying:
“The heading of Rule 3(1), Chapter VI of KER—‘Alteration of Date of Birth etc.’—permits not just correction of birth date but also of name, religion, and caste, through a duly notified competent authority.”
Read Also:- Personal Loans or EMIs Don’t Override Duty to Maintain Wife and Child: Delhi High Court
The court affirmed that since the Commissioner of Examinations has been notified as competent for date of birth changes, he also holds the authority to update religion and caste details.
Quoting constitutional principles, the court emphasized:
“If a person has changed his religion without coercion, fraud, or undue influence, such an act is protected under Article 25. He has the fundamental right to practice the religion of his choice.”
Read Also:- Madras High Court: Same-Sex Couples Can Form a Family Even Without Legal Marriage
Justice Singh relied on landmark rulings including Sarla Mudgal v. Union of India, Lily Thomas v. Union of India, Indian Young Lawyers v. State of Kerala (Sabarimala case), and Dr. M. Ismail Faruqui v. Union of India, reaffirming the precedence that one’s religious identity and practice are constitutionally safeguarded personal freedoms.
“The Constitution postulates every individual as its basic unit. The rights guaranteed under Part III are geared towards the recognition of the individual and their personal liberty.”
Read Also:- Delhi High Court Closes Plea After Successful Completion of Bar Association Elections
The High Court directed the education authorities to make the requested corrections in the SSLC record and held that the existing rules under KER 1959 are sufficient to accommodate such lawful changes.
Counsel for the Petitioner: Advocates Santheep Ankarath, P. Anirudhan
Counsel for the Respondents: Adv. Paravathy Kottol (GP)
Case No: WP(C) 41609 of 2024
Case Title: Sudhin Krishna C. S. v State of Kerala and Others
