Manipur High Court Orders Reissue of Certificates for Northeast’s First Transgender Doctor
Imphal, August 20, 2025 – In a landmark ruling, the Manipur High Court has directed the Board of Secondary Education Manipur (BOSEM), the Council of Higher Secondary Education Manipur (COHSEM), Manipur University, and the Manipur Medical Council to issue fresh educational and professional certificates to Dr. Beoncy Laishram, the Northeast’s first transgender doctor, reflecting her updated name and gender. The decision, delivered on August 19, 2025, by a single bench of Justice A. Guneshwar Sharma, marks a significant step toward affirming transgender rights in India, particularly in the realm of identity recognition in official documents.
Background of the Case
Dr. Beoncy Laishram, a 32-year-old resident of Kwakwa in Imphal West, made history in 2018 by becoming the first transgender medical doctor in Northeast India. Born male and originally named Boboi Laishram, she underwent gender reassignment surgery on October 8, 2019. Following the surgery, she was issued a transgender identity certificate by the District Magistrate of Imphal West under the Transgender Persons (Protection of Rights) Act, 2019, recognizing her new name, Beoncy Laishram, and her gender as female. Her Aadhaar, Voter ID, and PAN cards were subsequently updated to reflect these changes.
However, Dr. Laishram faced significant hurdles when she sought to update her educational and professional certificates. Her Class 10 and 12 certificates, MBBS degree, and Medical Council registration still listed her birth name, Boboi Laishram, and gender as male. Despite repeated requests in February 2024 to BOSEM, COHSEM, Manipur University, and the Manipur Medical Council, her pleas for updated certificates were denied. The refusal prevented her from pursuing postgraduate medical studies, as the inconsistency in her documents barred her from appearing for the NEET-PG exam. Frustrated by the bureaucratic resistance, Dr. Laishram approached the Manipur High Court through a writ petition (WP(C) No. 392 of 2024), seeking judicial intervention.
Court’s Ruling and Legal Basis
The court’s decision was grounded in the Transgender Persons (Protection of Rights) Act, 2019, and the Transgender Rules, 2020. Justice Sharma cited Sections 4, 5, 6, and 7 of the Act, which affirm a transgender person’s right to self-perceived gender identity and mandate the updating of official documents, including educational certificates, following gender reassignment. Section 20 of the Act further ensures that its provisions override any conflicting rules or regulations, a point the court emphasized in rejecting BOSEM’s argument that it lacked provisions to amend certificates.
The court ordered BOSEM, COHSEM, Manipur University, and the Manipur Medical Council to issue fresh certificates within one month, replacing “Boboi Laishram” and “male” with “Beoncy Laishram” and “female.” Additionally, the court directed the Chief Secretary of Manipur to issue instructions to all state establishments, as defined under Section 2(b) of the Act, to incorporate Sections 6 and 7 into their rules and bylaws. This directive aims to prevent future transgender individuals from facing similar bureaucratic obstacles, ensuring compliance with the Act without the need for judicial recourse.
Justice Sharma also addressed a minor typographical error in Dr. Laishram’s transgender certificate, ruling that it did not undermine her rights. The court rejected the argument that certificate updates must begin with BOSEM, noting that Manipur University had no objection to amending the MBBS certificate once prior certificates were updated. The ruling clarified that all institutions are independently obligated to comply with the Act.
In a notable departure from judicial practice, the court chose not to mask Dr. Laishram’s identity in its judgment. “She, being a pioneer and a qualified doctor, will serve as an inspiration to other transgender persons to seek justice,” Justice Sharma stated, emphasizing that Dr. Laishram was not a victim of a crime but a citizen asserting her constitutional rights under Articles 14, 15, 16, and 21 of the Indian Constitution, which guarantee equality, non-discrimination, and the right to life and personal liberty.
Impact and Significance
The ruling has been hailed as a historic victory for transgender rights in India, particularly in the Northeast, where societal and institutional barriers often exacerbate challenges for the transgender community. Dr. Laishram’s case highlights the systemic issues faced by transgender individuals in updating their identities across official documents, a process critical for accessing education, employment, and professional opportunities.
Transgender rights activist Bonita Pebam, based in Imphal, described the judgment as a triumph for the entire transgender community in the Northeast. “For too long, our people have been forced to fight endless legal and bureaucratic battles to assert their identity. This judgment sends a clear message that our rights are not negotiable,” she said. Another activist, Shanta Khurai, who supported Dr. Laishram’s legal battle, noted that the ruling sets a legal precedent for transgender individuals facing similar challenges. “Numerous trans individuals excel in various fields but struggle to secure jobs due to these obstacles. Dr. Beoncy’s experience is a living example of this,” Khurai added.
Lawyer Manoranjan S.K. emphasized the ruling’s broader implications, stating that it ensures uniform recognition of transgender identities across the region. The court’s directive to the Chief Secretary to enforce compliance with the Transgender Act is expected to streamline future requests for identity updates, reducing the need for litigation.
Community and Legal Perspectives
The judgment aligns with the Supreme Court’s landmark 2014 ruling in the NALSA case, which recognized transgender persons as a third gender and affirmed their right to self-perceived gender identity. The Manipur High Court’s decision reinforces this precedent, interpreting the Transgender Act as a tool to dismantle institutional barriers. Senior counsel Jayna Kothari, who represented Dr. Laishram, argued that the Act’s provisions extend to all official documents, including birth and educational certificates, a stance the court upheld.
The ruling also addresses practical challenges faced by transgender individuals. Dr. Laishram told that the judgment would “go a long way in easing the problems faced by transpeople and changing mindsets.” Her case underscores the real-world consequences of outdated records, such as exclusion from professional opportunities and the emotional toll of navigating bureaucratic resistance.
On platforms like X, the ruling has sparked discussions about transgender rights, with many praising Dr. Laishram’s courage and the court’s progressive stance. However, some posts reflect ongoing societal debates about transgender recognition, highlighting the need for continued advocacy and awareness.
Looking Forward
The Manipur High Court’s order is a significant milestone in advancing transgender rights, particularly in a region where cultural and social acceptance remains a work in progress. By mandating compliance with the Transgender Act across all state establishments, the ruling sets a framework for systemic change, ensuring that transgender individuals can access their rights without resorting to protracted legal battles.
Dr. Beoncy Laishram’s journey—from breaking barriers as the Northeast’s first transgender doctor to securing this legal victory—continues to inspire. As the first month’s deadline approaches for the issuance of her updated certificates, her case serves as a beacon of hope for transgender individuals across India, affirming their right to live with dignity and recognition.
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