Introduction:

In a significant judgment, the Supreme Court of India has ruled that an Aadhaar Card cannot be considered as conclusive proof for determining the age of a deceased victim in compensation cases. Instead, the Court placed its reliance on the School Leaving Certificate, which carries statutory recognition under Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015. The case arose when the High Court, relying on the date of birth mentioned in the deceased’s Aadhaar Card, calculated the age of the deceased incorrectly, resulting in a lower compensation for the family. The Supreme Court set aside this judgment, correcting the compensation amount and emphasizing the importance of statutory records over government-issued identity documents like Aadhaar for age verification.

The appeal was filed by the Legal Representatives of the deceased who challenged the High Court’s decision, claiming that the age of the deceased had been erroneously calculated based on his Aadhaar Card, rather than the School Leaving Certificate. The bench, comprising Justices Sanjay Karol and Ujjal Bhuyan, accepted the appellants’ arguments and corrected the compensation awarded, increasing the amount from Rs. 9,22,336/- to Rs. 15,00,000/-.

Background:

The case revolves around the compensation awarded following a fatal accident. The deceased’s family initially approached the Motor Accidents Claims Tribunal (MACT), which awarded them compensation of Rs. 19,35,400/-. However, the High Court later reduced this amount to Rs. 9,22,336/- by applying a lower age multiplier based on the age mentioned in the deceased’s Aadhaar Card. According to the Aadhaar Card, the deceased’s age at the time of the accident was 47 years, prompting the High Court to apply a multiplier of 13. Dissatisfied with this reduction, the legal representatives of the deceased challenged the High Court’s reliance on the Aadhaar Card.

In their appeal before the Supreme Court, the appellants argued that the High Court had made a critical error by using the date of birth from the deceased’s Aadhaar Card to determine his age. They asserted that the deceased was actually 45 years old at the time of the incident, as verified by his School Leaving Certificate, and that a multiplier of 14 should have been applied instead. This discrepancy in the age calculation resulted in a significant reduction in the compensation amount awarded to the family.

Plaintiff’s Arguments:

The appellants contended that the High Court had erred by accepting the date of birth mentioned on the Aadhaar Card, which should not be used as proof of age. They argued that the Aadhaar Card was meant to serve as proof of identity and not as definitive proof of age. The appellants further submitted that the School Leaving Certificate of the deceased, which had statutory recognition under Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015, should have been considered instead. They pointed out that under this section, a statutory hierarchy of documents is provided for determining age, with school records being the primary source.

The appellants referred to several legal precedents, emphasizing the consistent rulings of various High Courts, which held that Aadhaar Cards cannot be relied upon as proof of age. Some of the key precedents cited by the appellants include:

• Manoj Kumar Yadav v. State of M.P.:

The Madhya Pradesh High Court had held that the Aadhaar Card cannot be taken as conclusive proof of age when determining juvenility.

• Navdeep Singh & Anr. v. State of Punjab & Ors.:

The Punjab and Haryana High Court had ruled that Aadhaar Cards are not firm proof of age.

• State of Maharashtra v. Unique Identification Authority of India & Ors.:

The Bombay High Court had referred to a UIDAI circular, which stated that Aadhaar Cards should not be used to establish the date of birth, even though they can serve as proof of identity.

• Gopalbhai Naranbhai Vaghela v. Union of India & Anr.:

The Gujarat High Court had ruled that a person’s pension should be determined based on the date of birth mentioned in the School Leaving Certificate, setting aside discrepancies in the Aadhaar Card.

• Shabana v. NCT of Delhi:

The Delhi High Court recorded the UIDAI’s statement that an Aadhaar Card cannot be used as proof of date of birth.

The appellants argued that these precedents firmly established the principle that school records, especially School Leaving Certificates, should be prioritized over Aadhaar Cards when determining a person’s age.

Defendant’s Stand:

The respondents, represented by the insurance company IFFCO-TOKIO General Insurance Co., defended the High Court’s decision to rely on the Aadhaar Card for determining the deceased’s age. They argued that the date of birth mentioned in the Aadhaar Card could be considered a legitimate document for such purposes, as it is a government-issued identity card. The respondents contended that the reduction in compensation was reasonable, based on the date of birth listed in the deceased’s Aadhaar Card, which calculated his age to be 47 at the time of death.

However, the respondents failed to provide compelling legal precedent to counter the arguments put forth by the appellants regarding the statutory preference for School Leaving Certificates over Aadhaar Cards for age determination.

Court’s Judgment:

After reviewing the arguments from both sides, the Supreme Court, led by Justice Sanjay Karol, ruled in favour of the appellants. The Court held that the School Leaving Certificate, having statutory recognition under Section 94 of the Juvenile Justice Act, should be given precedence over the Aadhaar Card when determining age. The Court emphasized that Aadhaar Cards cannot be considered conclusive proof of age, as established by previous rulings from various High Courts.

The judgment authored by Justice Karol extensively discussed the inadequacy of the Aadhaar Card as proof of age. The Court referred to the UIDAI Circular No. 08 of 2023, which clearly stated that while Aadhaar Cards can serve as proof of identity, they are not meant to establish the date of birth. The bench noted that various High Courts, including the Madhya Pradesh, Punjab and Haryana, Bombay, Gujarat, and Delhi High Courts, have consistently ruled that Aadhaar Cards cannot be relied upon for determining age.

The Court concluded that the age of the deceased should be determined based on the date of birth mentioned in the School Leaving Certificate, which confirmed that the deceased was 45 years old at the time of the accident. Consequently, the appropriate age multiplier was 14, not 13, as applied by the High Court.

In light of these findings, the Supreme Court corrected the compensation amount to Rs. 15,00,000/-, increasing it from the Rs. 9,22,336/- awarded by the High Court. The Court also applied the law laid down in the case of National Insurance Co. Ltd. v. Pranay Sethi (2017), adjusting the prospects to 25% instead of the 30% initially applied by the MACT.