Manipur High Court: Transgender Person Entitled to Fresh Certificates with New Name and Gender
The Manipur High Court has held that a transgender person has the right to apply for revised certificates reflecting their self-adopted gender identity after gender reassignment surgery.
Justice A. Guneshwar Sharma, while deciding the case of Dr. Beoncy Laishram v. State of Manipur & Ors., directed educational institutions to issue fresh certificates to the petitioner with her new name and gender.
Case Background
The petitioner, originally registered as Boboi Laishram (male), underwent gender reassignment surgery in 2019. Her Aadhaar, Voter ID and PAN card were updated with her new identity as Beoncy Laishram (female). However, the Board of Secondary Education Manipur, the Council of Higher Secondary Education Manipur, and Manipur University refused to make similar corrections in her academic and professional certificates.
Left with no option, she approached the High Court seeking recognition of her new name and gender in her educational records.
Court’s Findings
The Court relied on the Transgender Persons (Protection of Rights) Act, 2019 and the landmark NALSA judgment of the Supreme Court. It held that:
- A transgender person has the right to a self-perceived gender identity.
- Upon gender reassignment surgery, they can apply for a revised certificate based on the medical proof issued by the hospital.
- Section 3 of the Act prohibits discrimination against transgender persons in education, employment, healthcare and other areas
The Court also noted that unlike many judgments where transgender petitioners’ names are masked, here the name was disclosed to serve as a beacon for others to claim their rights with dignity.
Court’s Direction
The High Court directed all educational institutions concerned to issue fresh certificates in the petitioner’s new name and gender. This decision, the Court said, is in line with constitutional guarantees of equality, dignity and non-discrimination under Articles 14, 15, 16 and 21.
