In a significant ruling, the Manipur High Court has affirmed the right of transgender individuals to have their educational and official documents reflect their self-perceived gender identity and chosen name. The judgment, delivered by Hon’ble Mr. Justice A. Guneshwar Sharma, directs educational boards and universities to issue fresh certificates aligning with a person’s affirmed gender.
The case involved Dr. Beoncy Laishram, a doctor who underwent gender reassignment surgery in 2019, transitioning from male to female. While she successfully updated her Aadhaar, Voter ID, and PAN cards, her requests to the Board of Secondary Education Manipur (BOSEM), the Council of Higher Secondary Education Manipur (COHSEM), and Manipur University to update her MBBS and other educational certificates were denied. The institutions cited a lack of provisions in their regulations for such changes.
The court firmly rejected this argument. It held that the Transgender Persons (Protection of Rights) Act, 2019, and its corresponding 2020 Rules create a mandatory legal framework. Sections 6 and 7 of the Act empower a District Magistrate to issue a certificate of identity and a revised certificate post-surgery, confirming a person’s new name and gender.
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Crucially, the court emphasized that this revised certificate must be recorded in all official documents. Rule 2(d) of the 2020 Rules, with its Annexure-I, explicitly includes "any education certificate issued by a school, board, college, university" in its list of official documents.
"The provisions of Sections 6 & 7 of the Act have to be read into the rules/bye-laws/regulations of the board in terms of the provision of Section 20 of the Act."
- Manipur High Court Judgment
The judgment further clarified that each educational "establishment" (as defined by the Act) has an independent obligation under Section 10 to effect these changes. A university cannot refuse to update a degree certificate simply because the school board hasn't yet updated the matriculation certificate. This removes a major procedural hurdle for individuals.
The court also dismissed a technical objection regarding a minor spelling discrepancy in the District Magistrate's certificate, calling it a simple typographical error that should not deny a fundamental right.
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Ultimately, the court allowed the petition and issued directives. The respondents (BOSEM, COHSEM, Manipur University, and the Manipur Medical Council) were ordered to issue fresh certificates to Dr. Laishram reflecting her name as ‘Beoncy Laishram’ and gender as ‘female’ within one month. Furthermore, the Chief Secretary of Manipur was directed to ensure all state establishments incorporate the provisions of the Transgender Act into their rules.
This judgment is a powerful reinforcement of the Supreme Court's landmark NALSA verdict, ensuring that the rights of transgender persons are practically implemented across all levels of bureaucracy and education, preventing them from being forced to litigate for basic recognition.
Case Title: Dr. Beoncy Laishram vs. The State of Manipur & Ors.
Case Number: WP(C) No. 392 of 2024
