In a landmark decision on 19 August 2025, the Manipur High Court in Dr Beoncy Laishram v. State of Manipur & Ors. [W.P. (C) 392 of 2024], reaffirmed the constitutional and statutory right of transgender persons to have their chosen name and gender reflected in all educational and professional records. The judgment marks a shift from symbolic recognition to operational enforcement of the Transgender Persons (Protection of Rights) Act, 2019 (TG Act) and the Rules 2020, ensuring that self-identification is not an abstract right but an enforceable legal duty.
Dr Beoncy Laishram, India’s first transgender doctor, transitioned in 2019 and obtained a transgender certificate and identity card under Sections 6 & 7 of the Act. Based on this, she also updated her Aadhar, PAN and Voter ID. Despite this, the Board of Secondary Education (BOSEM), the Council of Higher Secondary Education (COHSEM) and Manipur University (MU) refused to update her educational and professional records. The inconsistency prevented her from appearing for NEET-PG, compelling her to approach the Court.
The petition, filed by CLPR Constitution Defender Fellow, Kiyeka V. Arkha and argued by Senior Advocate Jayna Kothari, challenged the refusal as a violation of her rights under Articles 14, 15, 16 & 21 of the Constitution and Sections 6 & 7 of the TG Act. The key issue was whether a transgender person can directly invoke these provisions to seek reissuance of educational certificates, or whether relief depends on institutional bylaws.
The Manipur High Court held that institutional silence on transgender inclusion cannot override statutory rights under the Act. Accordingly, Sections 6 & 7 of the Act must be read into all institutional rules and bye-laws by virtue of Section 20, which provides that the Act’s provisions are “in addition to and not in derogation of” any other law. Educational certificates, listed in Annexure I of the 2020 Rules, are official documents that must reflect the affirmed name and gender of the transgender person. Further, it observed that each establishment, whether a board, university or professional body, is independently bound to make such corrections once a transgender certificate is produced.
The Court also relied on progressive judgments from the Madras and Karnataka High Courts, which recognised the right of transgender persons to have their name and gender changed in official records. These included Poojitha B.P. v. Karnataka Secondary Education Board, Christina Lobo v. State of Karnataka, and Jeeva v. State of Karnataka, amongst others.
Equally significant was the Court’s refusal to anonymise the petitioner’s name. Observing that Dr Beoncy is not a victim but a rights-bearing individual, the Court held that masking her identity would amount to treating her as one. Instead, by acknowledging her name, the judgment affirmed visibility as a sign of dignity and agency. This marks a shift from the protectionist framing of transgender persons toward a recognition of their autonomy and leadership in advancing rights discourse.
The Court directed all respondent institutions to issue fresh certificates reflecting Beoncy’s chosen name and gender within one month and mandated that Sections 6 & 7 be incorporated into the by-laws of all establishments in Manipur. Until such incorporation occurs, these provisions shall be deemed read into all existing institutional rules.
This judgment squarely places the right to gender identity within the broader constitutional framework of equality and dignity affirmed in NALSA v. Union of India, ensuring that no procedural barrier can impede its exercise.
It embeds the right to identity as a continuing constitutional guarantee, requiring every educational, professional or governmental authority to act affirmatively to update records in alignment with a person’s self-identified gender.
The judgment exemplifies how courts can give a transformative effect to welfare legislation by reading equality and dignity into administrative processes.
As Justice Sharma observed, this decision is “a torch to other transgender persons leading them to the path of access to justice.”
