Her Degrees Said 'Boboi', She is Dr. Beoncy. Read How She Forced the System to Accept Her Identity.

Imphal- In a landmark judgment, the Manipur High Court has directed multiple educational and medical councils to reissue all academic certificates for a petitioner, Dr. Beoncy Laishram, reflecting her changed name and gender identity. The ruling mandates that her certificates now show her as ‘Beoncy Laishram, female’ instead of her birth name, ‘Boboi Laishram, male’.

Justice A. Guneshwar Sharma, presiding over the case, delivered a comprehensive verdict, emphasizing that the provisions of the Transgender Persons (Protection of Rights) Act, 2019, and its corresponding Rules of 2020 must be read into all existing regulations of educational and official bodies. The court held that the right to self-identified gender and name is fundamental and must be reflected across all personal documents.

The petitioner, a 32-year-old medical professional, underwent gender reassignment surgery on October 8, 2019. Following the procedure, she obtained a revised identity certificate from the District Magistrate of Imphal West under Sections 6 and 7 of the Transgender Act, which recognized her as ‘Dr. Beoncy Laishram, female’.

This change was also updated in her Aadhaar, Voter ID, and PAN cards. However, her requests to the Board of Secondary Education Manipur (BOSEM), the Council of Higher Secondary Education Manipur (COHSEM), Manipur University, and the Manipur Medical Council to update her academic and professional certificates were consistently denied, prompting her to approach the High Court.

The respondents, particularly BOSEM, argued that their existing bylaws contained no provision for altering names and genders post-issuance of certificates. They also pointed out a typographical discrepancy in the DM-issued certificate, which listed her original name as ‘Boiboi’ instead of ‘Boboi’. The university and higher secondary council further contended that any correction must begin from the matriculation level upwards, not at an intermediate stage.

What the Court Said?

The court rejected these arguments outright. Justice Sharma stated, “The provisions of Sections 6 & 7 of the Act have to be read into the rules/bye-laws/regulations of the board in terms of the provision of Section 20 of the Act.” The judgment clarified that the Transgender Act is a special law designed to protect a vulnerable community, and its provisions hold supremacy over any general rules that may be silent on the matter.

Addressing the technical objection about the name spelling error, the court deemed it a minor typographical issue that should not impede the petitioner’s rights. “This is a simple typographical mistake and the right of the transgender person to change her first name and gender cannot be denied on this technical issue,” the order read.

The court also dismissed the argument that changes must be initiated from the first educational institution. It ruled that every ‘establishment’ under the Act has an independent obligation to effect changes upon receiving an application supported by a valid certificate from the District Magistrate. “Any establishment has an obligation under Section 10 of the Act to make necessary correction for the new name and gender of the transgender person... without waiting for such correction by the initial institute,” the judgment noted.

In a significant move to ensure systemic change, the court directed the Chief Secretary of the Government of Manipur to issue necessary instructions to all relevant establishments to incorporate the provisions of the Transgender Act into their bylaws. Until this is done, the provisions of Sections 6 and 7 of the Act will be deemed to be automatically read into all existing regulations.

The court also made a conscious decision not to anonymize the petitioner’s identity in the judgment, a departure from the practice in some High Courts. It reasoned that Dr. Laishram, as an educated professional and a pioneer, should be a visible inspiration for others in the transgender community to seek justice. “Masking her name in the judgment will amount to treating her as a victim of crime... she, being a pioneer in this field and well-educated person holding an MBBS degree, will be a source of inspiration to other transgender persons,” Justice Sharma observed.

The respondents have been given a one-month deadline to issue the fresh certificates. The judgment is expected to set a precedent, streamlining the process for transgender individuals across the state to update their official documents without having to resort to prolonged legal battles.