The Manipur High Court has ruled that a transgender person is entitled to have their changed name and gender updated in all educational certificates and official documents. Justice A. Guneshwar Sharma held that institutions cannot refuse such changes merely on the ground that their rules, bye-laws or regulations do not contain specific provisions for the same.
The Court emphasized that Sections 6 and 7 of the Transgender Persons (Protection of Rights) Act, 2019—which provide for recognition of a transgender person’s identity and updation of official documents following gender reassignment surgery—must be read into the rules of all boards and institutions. This, the Court said, is mandated by Section 20 of the Act read with Rule 2(d), Annexure-I of the Transgender Rules, 2020.
It further clarified that an intermediary or last educational institution, such as a university, need not wait for corrections to be made by the first institution the person attended. Every establishment, as defined under Section 2(b) of the Act, has an independent obligation under Section 10 to correct and update certificates to reflect the new name and gender of a transgender person.
The ruling came in response to a petition filed by Dr. Beoncy Laishram, a transgender woman whose academic and professional records still reflected her birth name, Boboi Laishram, and male gender. After undergoing gender reassignment surgery in October 2019, Dr. Laishram obtained updated legal identity documents including Aadhaar, Voter ID, and PAN card, reflecting her female gender and new name. Despite this, the Board of Secondary Education Manipur (BOSEM), Council of Higher Secondary Education Manipur (COHSEM), Manipur University, and Manipur Medical Council refused to issue corrected certificates.
Allowing her plea, the Court directed all the above institutions to issue fresh certificates to Dr. Laishram. It also ordered that the provisions of Sections 6 and 7 of the 2019 Act be formally incorporated in the rules and regulations of all establishments across Manipur. Until such formal incorporation is made, the Court held, these provisions shall be “deemed” to be read into all existing rules, bye-laws, and regulations by virtue of Section 20 of the Act.
The Court further instructed the Chief Secretary of Manipur to issue necessary directions to ensure compliance across all educational and professional bodies in the State.
Senior Advocate Jayna Kothari and Advocate Md. Murad Sareef represented the petitioner. Senior Advocate Y. Nirmolchan and Advocates Th. Sukumar, N. Khelemba, I. Denning, U. Augusta, and Anjan Prasad Sahu appeared for the respondents.
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