Kerala High Court Upholds Right to Religious Identity in Educational Records: Sudhin Krishna Case

Introduction

In the judgment of Sudhin Krishna C. S. v State of Kerala and Ors ^[1] the Kerala High Court reaffirmed the constitutional right of individuals to freely choose their religion and have their chosen identity reflected in official records. Delivered by Justice D.K. Singh, the ruling invoked Article 25 of the Constitution, which guarantees the freedom of conscience and religious practice. The case centered around a petitioner’s plea to amend his name and religion in his educational records, highlighting critical questions of religious freedom, administrative compliance, and individual autonomy.

Background of the Case

The petitioner, Sudhin Krishna C.S., was originally registered as Mohammed Riyazudeen C.S. in his school records by his father. Raised by his Hindu mother, Sudhin followed Hindu traditions and officially converted to Hinduism upon reaching adulthood, obtaining a gazette notification to confirm his new name and religion. Despite this, his educational records continued to reflect his former name and religion.

When he approached the District Educational Officer (DEO) to request corrections, his application was denied. The DEO argued that the Kerala Education Rules (KER), 1959, did not explicitly provide for such changes. Left with no recourse, the petitioner turned to the Kerala High Court, relying on previous decisions that had permitted similar amendments under Rule 3(1) of Chapter VI of the KER.

Rule 3(1), Chapter VI of the Kerala Education Rules (KER), governs the alteration of the date of birth or other essential details in school records. It prohibits arbitrary changes and mandates a formal process supported by valid documentation, such as a birth certificate or court order. In the case of Sudhin Krishna C. S. v. State of Kerala & Ors, the Kerala High Court interpreted this rule to extend beyond altering the date of birth, encompassing changes to name, caste, and religion in school records. Here, the Court rejected the government’s narrow interpretation of Rule 3(1), which initially limited corrections to the date of birth, affirming that the provision inherently allows for changes to personal details critical to identity. Citing constitutional rights under Article 25, the Court emphasised that administrative powers granted for one type of correction cannot be arbitrarily restricted. It directed the Commissioner of Examinations to amend the petitioner’s records, reinforcing the principles of personal liberty, self-determination, and the right to an accurate representation of one’s chosen identity in official documents.

Rival Contentions

Petitioner’s Contentions
The petitioner argued that Rule 3(1) of Chapter VI of the KER explicitly allows changes to details such as name, religion, and caste. He cited precedents like Naveed M.C. @ Noufal v. State of Kerala^[2] and Lohith S. v. State of Kerala ^[3]to assert that his right to religious freedom and identity under Article 25 of the Constitution was being violated by the respondents’ inaction.

Respondents’ Contentions
The respondents countered that the KER did not contemplate amendments to religious or caste details in educational records. They maintained that the scope of Rule 3(1) was limited to specific alterations, primarily the correction of dates of birth, and argued that the Commissioner of Examinations lacked the authority to make such changes.

Legal Provisions and Judgments

The Kerala High Court examined key legal and constitutional principles while deciding the case. Central to the judgment was Article 25 of the Indian Constitution, which guarantees the right to freedom of conscience and the liberty to profess, practice, and propagate religion, subject to reasonable restrictions. The Court also interpreted Rule 3(1), Chapter VI of the Kerala Education Rules (KER), 1959, which allows for changes in personal details, including name, religion, and caste. Drawing upon precedents, the Court relied on Smt. Sarla Mudgal v. Union of India^[4], which emphasized the constitutional right to religious freedom, and Indian Young Lawyers Association v. State of Kerala^[5], which advocated for non-discrimination in religious practice. These judgments reinforced the principles of autonomy and self-determination, enabling individuals to freely choose and reflect their religious identity without undue interference.

High Court Analysis

Justice D.K. Singh interpreted Rule 3(1) of Chapter VI of the KER to allow for changes not only in the date of birth but also in other personal particulars, including religion and caste. The court noted that the Commissioner of Examinations, already authorized to make corrections to dates of birth, was equally competent to amend records concerning religion and caste. The judgment also invoked Article 25 of the Constitution, affirming that the petitioner’s voluntary conversion, free from coercion or fraud, was constitutionally protected. Justice Singh emphasized that official records must reflect an individual’s chosen identity to uphold the principles of autonomy, equality, and religious freedom enshrined in the Constitution.

Final Decision

The court directed the respondents to make the necessary amendments to the petitioner’s educational records, ensuring that his chosen name and religion were accurately reflected. It clarified that Rule 3(1) of Chapter VI of the KER provides adequate legal support for such changes, reinforcing the petitioner’s fundamental rights.

Concluding Remarks

This judgment is a testament to the judiciary’s role in safeguarding individual freedoms and upholding constitutional principles. By recognizing the right to amend official records to reflect one’s chosen identity, the Kerala High Court has reinforced the values of personal autonomy, inclusivity, and respect for diversity. The decision not only affirms the right to religious freedom but also sets a precedent for administrative practices that align with fundamental rights, ensuring justice and equality in a pluralistic society.

For further details, write to contact@indialaw.in

^[1] Sudhin Krishna C.S. v. State of Kerala and Ors, (2025) INSC 311

^[2] Naveed M.C. @ Noufal v. State of Kerala, (2021) INSC 191

^[3] Lohith S. v. State of Kerala, (2024) INSC 4006

^[4] Smt. Sarla Mudgal v. Union of India, (1995) 3 SCC 635

^[5] Indian Young Lawyers Association v. State of Kerala, (2018) 10 SCC 689