Aadhaar Card Inadequate as Proof of Date of Birth: Supreme Court Ruling

The Supreme Court of India recently ruled that Aadhaar cards should not be used as proof of date of birth in legal cases. The ruling stemmed from a case involving compensation for a motor accident, where the age of the deceased was a key factor in determining compensation. The Court preferred a school leaving certificate over the Aadhaar card, emphasizing that the latter does not carry legal weight as evidence of age.

Background of the Case

The case involved the family of a motor accident victim. Initially, the Motor Accidents Claim Tribunal (MACT) granted the family compensation of Rs. 19,35,400/-, but this amount was reduced by the High Court to Rs. 9,22,336/-. The High Court used the deceased's Aadhaar card to estimate the age as 47, applying a multiplier of 13 in the calculation. However, the victim's family argued that the correct age was 45, as recorded in the school leaving certificate, which would mean a higher multiplier of 14 should apply, resulting in increased compensation.

Supreme Court's Rationale

A bench of Justices Sanjay Karol and Ujjal Bhuyan heard the appeal and concluded that the Aadhaar card is not a reliable document for establishing age. Instead, they referenced Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015, which gives precedence to school certificates as more authoritative evidence of age. The Court sided with the victim's family, supporting the claim that the deceased’s age should be determined based on the school certificate rather than the Aadhaar card.

Why Aadhaar Is Not Considered Reliable for Age Verification

Aadhaar cards are widely accepted for identity verification in India, but this Supreme Court ruling reinforces that they should not be treated as definitive proof of age. The Court cited a circular from the Unique Identification Authority of India (UIDAI), stating that Aadhaar is primarily for identity verification, not age confirmation. Several other high courts across India have ruled similarly, with notable cases reinforcing this perspective:

1. Manoj Kumar Yadav v. State of M.P. – The Madhya Pradesh High Court ruled that Aadhaar could not be used as conclusive proof of age, particularly in juvenile cases.

2. Navdeep Singh & Anr. v. State of Punjab & Ors. – The Punjab and Haryana High Court stated that Aadhaar lacks the reliability needed to serve as firm proof of age.

3. State of Maharashtra v. UIDAI and Ors. – The Bombay High Court referenced UIDAI’s directive, reiterating that Aadhaar serves as an identification tool but does not hold conclusive value for determining the date of birth.

4. Gopalbhai Naranbhai Vaghela v. Union of India & Anr. – The Gujarat High Court relied on a school certificate over an Aadhaar card to confirm the date of birth, emphasizing the limited role of Aadhaar in age verification.

5. Shabana v. NCT of Delhi – The Delhi High Court noted that Aadhaar should not be accepted as proof of birthdate, per the UIDAI’s clarification.

Implications of the Judgment

This ruling has implications for a variety of legal matters where age determination is essential, including compensation calculations in accident cases, juvenile justice proceedings, and pension claims. By reinforcing the value of school records, the Court clarifies that statutory documents hold greater reliability and legal weight in establishing a person’s age.

The ruling aligns with UIDAI’s position, as per Circular No. 08 of 2023, which highlights that while Aadhaar cards are suitable for identification purposes, they are insufficient for verifying date of birth. This stance ensures consistency and clarity in how age should be proven in legal settings, prioritizing documents like school certificates that are recognized under the law.

Court’s Final Decision on Compensation

With this decision, the Supreme Court directed that the age of the deceased be established based on the school leaving certificate, not the Aadhaar card. This adjustment led to a revised calculation of the compensation amount, from Rs. 9,22,336/- to Rs. 15,00,000/-. This revised amount includes 8% interest from the date of the original claim petition, as ordered by the Court. The ruling serves as an important precedent in similar cases, ensuring that families receive fair compensation based on legally accurate information.

Case Citation

The case, titled Saroj & Ors. v. IFFCO-TOKIO General Insurance Co. & Ors., is documented as 2024 LiveLaw (SC) 837. The Supreme Court's decision to align with statutory documents over Aadhaar will likely influence future cases concerning age determination and compensation.

Conclusion

In summary, the Supreme Court’s judgment highlights the limited scope of the Aadhaar card for age verification, preferring documents with statutory backing, like school certificates. This decision impacts various legal proceedings, ensuring that accurate and lawful evidence is used for critical determinations, such as age in compensation cases. The ruling not only reinforces the value of statutory documents but also sets a clear guideline for future cases where the Aadhaar card might otherwise be misinterpreted as conclusive proof of age.