Court Affirms Transgender Persons’ Right to Update Educational Records
The Manipur High Court has ruled that transgender persons are entitled to have their updated name and gender reflected in all educational certificates and official documents. The decision was delivered by Justice A. Guneshwar Sharma, who emphasized that the Transgender Persons (Protection of Rights) Act, 2019 must be read into the rules and regulations of all educational boards and institutions.
The Court dismissed the argument that institutions lack specific provisions in their bye-laws to allow such changes. It clarified that Sections 6 and 7 of the 2019 Act, along with the Transgender Rules of 2020, mandate recognition and updation of a transgender person’s identity after gender reassignment surgery.
Legal Provisions Applied in the Ruling
The Court further held that intermediary institutions such as universities or higher boards cannot delay updates until the first institution makes corrections. Instead, every establishment has a legal obligation to recognize and update the name and gender of transgender persons in their records.
Case of Dr. Beoncy Laishram
The ruling came in response to a plea filed by Dr. Beoncy Laishram, a transgender woman and medical professional. After undergoing gender reassignment surgery in 2019, Dr. Laishram updated her identity in official documents, including Aadhaar, PAN, and Voter ID cards. However, educational boards and universities in Manipur refused to revise her academic certificates, which still displayed her birth name, Boboi Laishram, and male gender.
Dr. Laishram approached the High Court seeking fresh certificates from the Board of Secondary Education Manipur (BOSEM), Council of Higher Secondary Education Manipur (COHSEM), Manipur University, and the Manipur Medical Council.
Court Orders Educational Boards to Issue Fresh Certificates
After examining the case, the High Court directed all concerned institutions to issue fresh certificates reflecting Dr. Laishram’s new name and female gender. The Court also mandated that all establishments in Manipur must incorporate Sections 6 and 7 of the Act into their rules, regulations, and bye-laws.
Until such incorporation is formally carried out, the Court held that these provisions will be deemed to be part of all existing regulations. The Chief Secretary of Manipur has been instructed to issue directions ensuring compliance.
Significance of the Judgment
This judgment strengthens transgender rights in India, ensuring that academic and professional records align with a person’s legally recognized gender identity. It sets a precedent that institutions cannot deny updates on the pretext of missing rules or procedures.
By upholding the spirit of the Transgender Persons (Protection of Rights) Act, 2019, the Court has reinforced the right to dignity, identity, and equal treatment for transgender individuals in educational and professional spaces.
