In a significant judgment today, the Supreme Court of India set aside a High Court ruling that accepted the date of birth mentioned in an Aadhaar Card to determine the age of a victim in a motor accident compensation case. The bench, comprising Justices Sanjay Karol and Ujjal Bhuyan, clarified that the Aadhaar Card is not suitable as conclusive proof of age, instead emphasizing the importance of statutory documents, such as a school leave certificate, for such determinations.
Context of the Case
The case revolves around a tragic motor accident that resulted in a claim for compensation of ₹19,35,400/- decided by the Motor Accidents Claim Tribunal (MACT). However, the High Court reduced the compensation to ₹9,22,336/-, primarily relying on the age reflected in the Aadhaar Card. The High Court calculated the deceased’s age as 47 years and applied an age multiplier of 13 for compensation calculation.
The legal representatives of the deceased challenged this decision, arguing that the High Court erred in using the Aadhaar Card as the basis for determining age. They pointed to the deceased’s school leave certificate, which indicated that he was actually 45 years old at the time of the incident, warranting an application of the multiplier of 14 instead.
Key Findings of the Supreme Court
Justice Karol, while authoring the judgment, scrutinized several previous High Court decisions regarding the admissibility of the Aadhaar Card as proof of age. Some notable cases referenced include:
- Manoj Kumar Yadav v. State of M.P.: The Madhya Pradesh High Court ruled that the age mentioned in the Aadhaar Card could not be treated as conclusive proof of age concerning claims of juvenility, as per Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015.
- Navdeep Singh & Anr. v. State of Punjab & Ors.: This ruling from the Punjab & Haryana High Court reiterated that Aadhaar Cards do not serve as “firm proof of age.”
- State of Maharashtra v. Unique Identification Authority of India & Ors.: The Bombay High Court referred to UIDAI Circular No. 08 of 2023, clarifying that while the Aadhaar Card can establish identity, it cannot be regarded as proof of date of birth.
- Gopalbhai Naranbhai Vaghela v. Union Of India & Anr.: The Gujarat High Court prioritized the date mentioned in the school leaving certificate over that in the Aadhaar Card for pension release.
- Shabana v. NCT of Delhi: The Delhi High Court noted the UIDAI’s position that an Aadhaar Card may not be used as proof of date of birth.
The Supreme Court concluded that the Aadhaar Card’s status as proof of age was inadequate, stating, “That being the position, as it stands with respect to the determination of age, we have no hesitation in accepting the contention of the claimant-appellants, based on the School Leaving Certificate.”
Compensation Determination
After recognizing the school leaving certificate as a more reliable document for establishing age, the Supreme Court applied a multiplier of 14 for calculating compensation, rather than the 30% increase previously set by MACT for future prospects. The Court ordered the respondents to pay ₹15,00,000/- as compensation to the appellants.
In delivering the judgment, the Court aimed to ensure just compensation, rounding off the total amount of ₹14,41,500/- to ₹15,00,000/- with an interest rate of 8% from the date of filing the claim petition. The compensation is to be released to the rightful claimants in the manner directed by the Tribunal.
Conclusion
This ruling by the Supreme Court underscores the importance of relying on statutory documents for age determination in compensation cases, rather than informal or non-statutory sources like the Aadhaar Card. By reaffirming the need for more authoritative proof, the Court aims to uphold justice and ensure that victims and their families receive the compensation they rightfully deserve.
Case Title: Saroj & Ors. v. IFFCO-Tokio General Insurance Co. & Ors., C.A. No. 012077 – 012078 / 2024
