Facts: Petitioner No.1 is a twelve-year-old girl born out of a sexual offence committed against her mother, Petitioner No.2. Although a DNA report confirmed paternity, the biological father (the accused) entered into a settlement in 2022 renouncing all guardianship and roles in the child's life. The child has been raised exclusively by her mother, who belongs to the Mahar Scheduled Caste community, whereas the father's name and "Maratha" caste were initially recorded in school documents. The petitioners sought to change the minor's name and caste entry in school records to reflect the mother's identity and caste. The Education Department rejected this request, citing that the Secondary School Code does not permit such alterations.
Procedural Posture: The petitioners filed a Writ Petition under Articles 226 and 227 of the Constitution of India before the Bombay High Court, challenging the rejection order dated June 2, 2025.
Issue: Whether school authorities are justified in refusing to correct a minor's name and caste entry in school records when the child is raised exclusively by a single mother and the paternal ties are legally and functionally severed.
Holding: No. The High Court quashed the rejection order and directed the authorities to correct the name and enter the mother's caste in the school records, facilitating the process for a formal caste certificate.
Reasoning: The Court reasoned that Article 21 protects the right to an identity not forcibly tethered to an absent parent, especially when such a link causes social stigma. Under Article 14, the presumption that identity must flow through the father is a patriarchal construct that violates substantive equality in cases of single motherhood. Relying on the Full Bench decision in Janabai v. State of Maharashtra, the Court held that "obvious mistakes" in school records include entries that are factually incongruent with a child's lived social reality. Furthermore, following Rameshbhai Dabhai Naika v. State of Gujarat, the Court affirmed that caste is not determined solely by biological descent but by the milieu in which the child is reared. Forcing the child to carry the father's caste, when she has no ties to his community, would defeat the purpose of constitutional protections for dignity and social justice.