Student Can't Suffer For Clerical Error: MP High Court Quashes Order Denying Photo Correction In Marksheets

The Madhya Pradesh High Court's Gwalior Bench has held that a student cannot be made to suffer for a clerical error committed by examination authorities, quashing an order that refused to correct a wrongly uploaded photograph across three years of a nursing student's academic records.

Justice Milind Ramesh Phadke was hearing a writ petition filed by Roopa Yadav, a General Nursing and Midwifery student, who challenged an order dated October 24, 2025, by which the Madhya Pradesh State Nurses Registration Council rejected her request to correct her photograph on her marksheets. Shri Jitendra Kumar Sharma, appearing with Ms Krati Sachdev, represented the petitioner before the court.

According to the petition, Yadav was admitted to the GNM course for the 2019-20 session at a college recognised by the Council. She had submitted her correct photograph at the time of admission, and it was duly affixed to the admission form and register. However, when her first-year admit card was issued after online registration, she found that someone else's photograph had been uploaded in her place. The college assured her the error would be corrected, but she was still permitted to appear in the examination with the mismatched photograph on her admit card.

The same incorrect photograph went on to appear on her first, second, and third year marksheets, despite the college twice writing to the Council, in October 2021 and August 2022, asking it to rectify the mistake. A further representation was filed in June 2024, and the petitioner even sought information under the Right to Information Act on the status of her complaint, but received no relief. Having earlier approached the court once before and been directed to file a fresh representation, she returned to the High Court after the Council rejected that representation as well.

Counsel for the petitioner argued that Yadav had never been accused of fraud, misrepresentation, or impersonation, and that the mistake originated entirely with the authorities during online data upload, not with her. It was submitted that the Council could not now refuse to correct a clerical error after having permitted her to sit for all three years of examinations, evaluated her papers, and declared her results.

The Council, on the other hand, contended that the petition suffered from delay, since Yadav had known of the discrepancy since 2020 but approached the court only five years later. It also argued that its marksheets were generated purely on the basis of data uploaded by the college, that its own records showed consistency between the enrolment photograph and the marksheets, and that there was no statutory procedure for altering a photograph on official records after such a lapse of time. Any error, it said, lay with the college or the petitioner, not the Council.

Rejecting this position, the court, after perusing the record, found that the petitioner's original photograph was consistently reflected in the admission register and application form maintained by the college, even though the wrong photograph had somehow entered the online system during enrolment. The court observed that "the respondents have not alleged anywhere that the petitioner had indulged in impersonation, fraud, or any malpractice," and that no enquiry into her identity had ever been conducted despite the discrepancy being flagged repeatedly.

The bench held that "the petitioner cannot be made to suffer on account of a clerical or technical mistake committed during the online registration process, particularly when the original institutional records consistently establish her identity," and concluded that the Council's rejection of her request was "arbitrary, unreasonable, and unsustainable in law."

Quashing the October 2025 order, the court directed the authorities to verify Yadav's identity from the original admission records, including the admission register and application form, and to correct her photograph in all official documents. Fresh, corrected marksheets and related records must be issued within six weeks of the receipt of a certified copy of the order, with no order as to costs.

Case Title: Smt Roopa Yadav v. The State of Madhya Pradesh and Others

Date of Order: July 20, 2026

Bench: Justice Milind Ramesh Phadke