Supreme Court Declares Aadhaar Not Valid Proof of Birth Date
The Supreme Court of India recently overturned a High Court ruling that had accepted the Aadhaar card as sufficient proof of date of birth in determining the age of a victim in a motor accident compensation case. A bench of Justices Sanjay Karol and Ujjal Bhuyan emphasized that an Aadhaar card should not be relied upon for age verification in such cases, advocating instead for using a school leaving certificate, which has statutory recognition under Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015.
Case Background
The case involved a motor accident compensation claim where the Motor Accidents Claims Tribunal (MACT) initially awarded the deceased’s legal representatives ?19,35,400. However, the High Court subsequently reduced this amount to ?9,22,336 after recalculating the deceased's age based on the birth date listed in his Aadhaar card, applying an age multiplier of 13 by concluding the victim was 47 years old at the time of death.
The deceased’s legal representatives, dissatisfied with the High Court’s decision, argued that the High Court wrongly relied on the Aadhaar card for calculating the deceased’s age. They cited the deceased’s school leaving certificate, which indicated his age was 45 years, and contended that a multiplier of 14 should apply instead. The Supreme Court agreed with this argument, supporting the school leaving certificate as the more reliable document for age verification.
Aadhaar Card’s Limitations as Proof of Age
In its ruling, the Supreme Court highlighted several precedents from other High Courts regarding the suitability of Aadhaar as proof of age:
Manoj Kumar Yadav v. State of M.P. – The Madhya Pradesh High Court ruled that Aadhaar cannot conclusively establish age, especially in matters of juvenile status, due to the requirements outlined in Section 94 of the Juvenile Justice Act.
Navdeep Singh & Anr. v. State of Punjab & Ors. – The Punjab & Haryana High Court held that Aadhaar does not constitute definitive proof of age.
State of Maharashtra v. Unique Identification Authority of India and Ors. – The Bombay High Court referred to a UIDAI circular stating that while Aadhaar can verify identity, it is not definitive proof of date of birth.
Gopalbhai Naranbhai Vaghela v. Union Of India & Anr. – The Gujarat High Court ruled in favor of using the date on the school leaving certificate rather than Aadhaar for determining age, particularly for pension claims.
Shabana v. NCT of Delhi – The Delhi High Court echoed UIDAI’s stance that Aadhaar should not be used as proof of date of birth.
The Supreme Court referred to these cases to reinforce its position that the Aadhaar card, while useful for identity verification, lacks the reliability required for confirming an individual’s age.
Decision and Compensation Adjustment
Given the school leaving certificate as valid proof, the Supreme Court adjusted the age multiplier to 14 and recalculated the compensation. The Court applied the legal principles established in the National Insurance Co. Ltd. v. Pranay Sethi (2017) case, setting the future prospects at 25% instead of the 30% initially calculated by the MACT.
Consequently, the Court directed the respondents to pay a revised amount of ?15,00,000 as compensation to the appellants. The final judgment reads, "The appeals are allowed; the total amount, i.e., ?14,41,500, in the interest of just compensation, is rounded off to ?15,00,000 with 8% interest from the date of filing of the claim petition to be released to the rightful claimants in the manner directed by the Tribunal."
Click here to read/download the judgment
Case Citation
- Case Title: Saroj & Ors. versus IFFCO-Tokio General Insurance Co. & Ors., C.A. No. 012077 - 012078 / 2024
- Citation: 2024 LiveLaw (SC) 837
Legal Representation
- For the Petitioners: Ms. Srishti Choudhary, Advocate; Ms. Shefali Choudhary, Advocate; Ms. Namita Choudhary, Advocate-on-Record
- For the Respondents: Mr. Suyash Vyas, Advocate; Mr. Gopal Singh, Advocate-on-Record; Mr. Anil Hooda, Mr. Shafik Ahmed, Mr. Ajay Sharma, Mr. Sunny, Mr. Satendra Singh Baghel, Mr. S. Srinivasa Chary, Mr. Manoj Kumar, Ms. Parul Priya, Ms. Anupama Singh, and Mr. Varun Mishra, Advocate-on-Record
Why Aadhaar Falls Short as Proof of Date of Birth
Aadhaar, a widely-used identification document issued by the Unique Identification Authority of India (UIDAI), includes an individual's date of birth. However, the Supreme Court has clarified that Aadhaar should not be accepted as valid proof of birth date. The Court noted that Aadhaar primarily serves as an identity document, and its process does not involve thorough verification of birth details like a birth certificate or passport.
The data verification process for Aadhaar issuance involves minimal scrutiny of the provided information, especially regarding date of birth. Since Aadhaar is meant for identification rather than authentication of age or origin, the Court emphasized that relying solely on Aadhaar for critical verifications like date of birth could lead to inconsistencies. This ruling highlights the need for robust documentation and underscores the importance of verifying date of birth through other legally acceptable documents.
Implications of the Ruling
This decision by the Supreme Court has significant implications, affecting various segments of society, including students, job applicants, government employees, and retirees who might have relied on Aadhaar as proof of age. Without a secondary document confirming their date of birth, individuals may face challenges in situations where accurate age verification is crucial, such as school admissions, employment verification, and retirement benefits.
For organizations that previously accepted Aadhaar for verification, this ruling necessitates revisiting and revising their document acceptance policies. By emphasizing the importance of correct age verification, the Supreme Court aims to ensure that individuals use more accurate documents, ultimately promoting more reliable record-keeping.
What Documents are Suitable for Date of Birth Verification?
In light of this ruling, the following documents are considered suitable and legally acceptable for date-of-birth verification in India:
Birth Certificate: Recognized as the most reliable proof of date of birth, the birth certificate is issued by municipal authorities or other designated government bodies. It remains the gold standard for age verification in India.
Passport: Issued after a stringent verification process, a passport is another document widely accepted as reliable proof of date of birth. Given its high level of credibility, the passport is often used in legal and official settings where identity and age verification are critical.
School Leaving Certificate: For individuals who may not have a birth certificate or passport, a school leaving certificate can serve as an alternative document for verifying their date of birth. Schools and educational boards in India maintain strict records that are legally recognized for age verification.
PAN Card and Voter ID: Although these documents also include the date of birth, their primary purpose is not age verification, and they may be accepted only under specific circumstances.
How Legals365 Can Assist with Compliance and Documentation
For individuals and organizations navigating the complexities of document verification and compliance with the latest legal standards, Legals365 provides comprehensive support. Our team of legal experts can guide you on the correct documentation to use for age and identity verification, ensuring compliance with the latest regulations. Legals365 also assists clients in obtaining critical documents, such as birth certificates and passports, and provides legal counsel for issues surrounding identity verification.
By staying informed about the latest rulings and regulatory updates, Legals365 helps clients avoid compliance issues and ensures that the correct documentation is submitted for verification purposes. Whether you need assistance with preparing documentation for a legal requirement or verifying information for an official application, Legals365 offers personalized solutions tailored to your needs.
Impact on Government Policies and Public Services
With Aadhaar’s use restricted as proof of birth date, government bodies and public institutions will need to revise their policies. Services such as school admissions, government schemes, and employment verification often depend on age verification, which previously might have accepted Aadhaar. This ruling compels these institutions to update their document requirements to exclude Aadhaar as primary proof of date of birth, aligning their processes with the Supreme Court’s guidelines.
This change also affects online services, as many public and private platforms previously accepted Aadhaar as a one-stop ID for various applications. In light of the ruling, institutions may now require individuals to present additional documents to authenticate their age. For citizens, this may mean gathering additional documentation for certain applications, and the ruling serves as a reminder to maintain proper, government-recognized records of one’s date of birth.
The Role of UIDAI and Potential Aadhaar Modifications
The UIDAI, the governing body responsible for issuing Aadhaar, may need to address public concerns about the usability of Aadhaar in the future. While Aadhaar remains one of the most accessible identity proofs, this ruling emphasizes its limitations. UIDAI may consider refining Aadhaar’s verification process or issuing guidelines clarifying Aadhaar's scope of use for individuals and institutions.
For example, the UIDAI might introduce mechanisms to distinguish Aadhaar primarily as an identity document rather than proof of age or origin. Additionally, UIDAI may enhance its public communication to ensure that individuals and organizations understand Aadhaar's limitations in contexts requiring accurate birth verification.
Conclusion
The Supreme Court’s ruling declaring Aadhaar unsuitable as proof of date of birth highlights the importance of using accurate, government-verified documents for age verification. This decision reinforces the need for proper documentation and encourages individuals and institutions alike to maintain high standards in identity verification. For those seeking assistance with documentation and compliance, Legals365 offers expert legal support to ensure you navigate these requirements confidently.
As policies continue to evolve, staying informed about compliance requirements is essential. By partnering with Legals365, individuals and organizations can ensure that their documentation practices align with legal standards, providing security, reliability, and peace of mind in a constantly changing regulatory landscape.
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