Dr. Beoncy Laishram v. The State of Manipur & Ors.

June 17, 2024 | Anish Saha
Case No. WP (C) 392/2024 Date of Filing 06/06/2024 Status Disposed Petitioners Dr. Beoncy Laishram Respondents 1. State of Manipur, represented by Director, Department of University and Higher Education 2. The Director, Directorate of Education (School) 3. The Chairman, Board of Secondary Education 4. The Chairman, Council of Higher Secondary Education 5. The Registrar, Manipur University 6. THe Registrar, manipur medical Council

CLPR represented Dr Beoncy Laishram, a practising doctor at Rangini Memorial Charitable Clinic in Manipur, who took a significant step by filing a petition before the Hon’ble High Court of Manipur seeking directives against the respondents for refusing to issue fresh educational certificates recognizing her changed name and gender identity. This move is noteworthy not only for its legal implications but also for Dr Laishram’s courage in speaking out against discrimination faced by trans individuals, highlighting the need for greater understanding and acceptance in society.

 

Dr. Laishram’s journey has not been easy. Born as Boboi Laishram, she underwent gender reassignment surgery and legally changed her name to Beoncy Laishram and her gender to female. However, despite providing all necessary documents, the respondents denied her request for fresh educational certificates, citing the need for a court order. Her attempt to pursue higher education was hindered by the lack of recognition of her changed name and gender. This refusal forced Dr. Laishram to live a life that did not align with her true identity, prompting her to seek legal recourse.

 

Her case is rooted in the Constitution, citing violations of fundamental rights to life, equality, and gender identity under Articles 14, 15, 19(1)(a), and 21. She also drew strength from the Supreme Court’s judgment in National Legal Services Authority v. Union of India (2014), a landmark case recognising the right to self-identify gender and mandated legal recognition of transgender persons’ self-identified gender.

 

Dr Laishram’s plea was not just about her individual case; it has far-reaching implications for the transgender community in India, especially in the Northeastern part of India. By seeking a writ of mandamus directing the respondents to issue fresh educational certificates reflecting her changed name and gender, Dr Laishram paved the way for others to follow in her footsteps. Her courage and determination are a beacon of hope for those struggling to find acceptance and recognition in a society often hostile to transgender individuals.

 

On 19 August 2025, the High Court of Manipur disposed of the writ petition. The Court held that a transgender person who has obtained a certificate of identity under Section 6 or a revised certificate under Section 7 of the Transgender Persons (Protection of Rights) Act, 2019 is entitled to have their name and gender updated in all official records, including educational certificates.

 

The Court observed that the absence of enabling provisions in the bye-laws or regulations of educational institutions cannot override the statutory rights conferred by the Transgender Persons (Protection of Rights) Act, 2019 and the Transgender Persons (Protection of Rights) Rules, 2020.

 

Importantly, the Court directed that the petitioner’s name should not be anonymised in the judgment, noting that anonymisation would wrongly equate her with victims of crime and would discourage the visibility of transgender persons asserting their rights.

 

The respondents were directed to issue fresh educational and professional certificates reflecting the petitioner’s affirmed name and gender.

 

The case was accordingly disposed of.

Case No. WP (C) 392/2024 Date of Filing 06/06/2024 Status Disposed Petitioners Dr. Beoncy Laishram Respondents 1. State of Manipur, represented by Director, Department of University and Higher Education 2. The Director, Directorate of Education (School) 3. The Chairman, Board of Secondary Education 4. The Chairman, Council of Higher Secondary Education 5. The Registrar, Manipur University 6. THe Registrar, manipur medical Council