Kerala High Court Upholds Right to Update School Records After Religious Conversion

Kochi, 4 June 2025: In a significant ruling, the Kerala High Court on Wednesday held that individuals who voluntarily convert to another religion have the constitutional right to update their school records to reflect the change. The Court delivered the verdict in response to a petition filed by a man who converted from Islam to Hinduism and sought to update his name and religion in his educational certificates.

Justice D.K. Singh, who presided over the case, affirmed that the right to freely profess, practise, and propagate religion under Article 25 of the Constitution also includes the right to voluntarily change one’s religion and have such a change duly recorded in official documents. “If a person has changed his religion without any coercion, fraud, or undue influence, such an act is protected under the Constitution of India,” the Court observed.

The petitioner, born to a Muslim father and a Hindu mother in Palakkad district, was registered in school as ‘Mohammed Riyazudeen CS’ with his religion marked as ‘Islam, Mappila’. Raised in the Hindu tradition by his mother, he later chose to formally embrace Hinduism. He converted through the Arya Samaj and published a gazette notification declaring his new identity as ‘Sudhin Krishna CS’.

Seeking to update his school records—specifically, his Secondary School Leaving Certificate (SSLC)—to reflect these changes, the petitioner submitted a request to the relevant authorities. However, the authorities rejected his application, claiming that the Kerala Education Act and Rules did not contain provisions for altering the recorded caste or religion in school documents.

In response, the petitioner approached the High Court, arguing that this rejection contravened Rule 3(1) of the Kerala Education Rules, 1959. This rule, he contended, explicitly provides for the correction or updating of a student’s name, caste, and religion in school records.

Appearing for the state of Kerala, government pleader Parvathy Kottol opposed the petitioner’s arguments on multiple grounds. She argued that no specific government authority had been officially designated under Rule 3(1) to make such changes to religion or caste in school records. She also maintained that, by a previous government order, the Commissioner of Examinations was empowered to handle only corrections related to date of birth.

Rejecting these arguments, the High Court held that Rule 3(1), Chapter VI of the Kerala Education Rules, 1959, authorises updates to a student’s name, caste, and religion, in addition to date of birth. The court clarified that the same official who handles date of birth corrections also has the authority to process changes related to name, caste, and religion.

The Court directed the Commissioner of Examinations to promptly process the petitioner’s request, emphasising that administrative limitations cannot override fundamental rights.

The ruling in Sudhin Krishna CS v. State of Kerala & Ors. [2025:KER:36913] upholds every citizen’s fundamental right to religious freedom and ensures that this freedom is recognised in official records.

Source: www.verdictum.in

Image Source: ecommitteesci.gov.in