Supreme Court Upholds School Leaving Certificate Over Aadhar Card for Age Verification in Motor Accident Compensation Claims

Introduction

In the landmark case of Saroj v. IFFCO-Tokio General Insurance Co. (2024 INSC 816), the Supreme Court of India addressed critical issues pertaining to the verification of a deceased individual's age in the context of motor accident compensation claims. The case emerged from a tragic incident on August 4, 2015, where Silak Ram lost his life in a motorcycle accident, leading his wife and sons to file a claim against IFFCO-Tokio General Insurance Company. The primary contention revolved around conflicting dates of birth recorded in the deceased's Aadhar Card and School Leaving Certificate, influencing the calculation of compensation based on age-dependent multipliers.

Summary of the Judgment

The Supreme Court reviewed the appellant's challenge against the High Court's decision to reduce the compensation awarded by the Motor Accident Claims Tribunal (MACT). The High Court had relied on the Aadhar Card, which indicated the deceased's date of birth as January 1, 1969, making him 47 at the time of the accident and applying a multiplier of 13 for compensation calculation. The claimants disputed this, presenting a School Leaving Certificate that recorded the date of birth as October 7, 1970, implying an age of 45 and a higher multiplier of 14.

The Supreme Court sided with the claimants, emphasizing that the School Leaving Certificate holds statutory recognition and should take precedence over the Aadhar Card for age verification purposes. Consequently, the Court reinstated the original compensation award, adjusted the multiplier to 14, and increased the interest rate to 8%.

Analysis

Precedents Cited

The judgment extensively referenced several High Court decisions that collectively established a judicial reluctance to accept the Aadhar Card as conclusive proof of age. Notable cases include:

Manoj Kumar Yadav v. State of M.P. (2023 SCC OnLine MP 1919) - The Madhya Pradesh High Court held that the Aadhar Card cannot be conclusively used to establish age in juvenile justice contexts.
Shahrukh Khan v. State of M.P. (2023 SCC OnLine MP 2740) - Reinforced the primacy of the School Leaving Certificate over the Aadhar Card for age verification.
Navdeep Singh v. State Of Punjab (2021 SCC OnLine P&H 4553) - The Punjab & Haryana High Court determined that Aadhar Cards are not "firm proof of age" under the Prohibition of Child Marriage Act.
Parvati Kumari v. State of U.P. (2019 SCC OnLine All 7085) - The Allahabad High Court echoed similar sentiments regarding the Aadhar Card's insufficiency as age proof.
Other instances from the Himachal Pradesh and Kerala High Courts further solidified this stance.

Additionally, the Supreme Court referenced the Unique Identification Authority of India's (UIDAI) Circular No. 08 of 2023, which explicitly states that the Aadhar Card is not per se proof of date of birth.

Legal Reasoning

The Supreme Court emphasized the principle that appellate courts should not substitute their views for those of lower courts unless there is a clear error such as perversity or illegality. In this case, the High Court's reduction of compensation was based on the Aadhar Card's date of birth, which the Supreme Court identified as an error given the statutory recognition of the School Leaving Certificate.

The Court highlighted that Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015, mandates age determination preferably through the School Leaving Certificate or equivalent documents before considering other proofs like the Aadhar Card. This statutory framework necessitates prioritizing documents that hold legal recognition over those primarily serving as identity proofs.

Furthermore, the Supreme Court analyzed the purpose behind the Aadhar Scheme, noting that while it effectively serves as a unique identity mechanism with robust biometric verification, its role does not extend to being an authoritative source for age determination in legal contexts.

Impact

This judgment sets a significant precedent in the realm of motor accident compensation claims and beyond. By affirming the primacy of statutory documents like the School Leaving Certificate over the Aadhar Card for age verification, the Supreme Court ensures that compensation calculations, which are sensitive to the deceased's age, are based on reliable and legally recognized evidence. This decision mitigates potential discrepancies arising from conflicting documents and upholds the integrity of compensation frameworks.

Additionally, the increase in the interest rate from the High Court's 6% to the Supreme Court's 8% underscores the Court's commitment to ensuring just compensation, reflecting the financial impact on the claimants more accurately.

Complex Concepts Simplified

Aadhar Card as Proof of Age

Despite being a widely accepted identification tool in India, the Aadhar Card is not deemed an authoritative proof of age by the Supreme Court. This is because its primary function is to establish unique identity through biometric data, not to serve as a legal document certifying age.

Multiplier in Compensation Calculation

In motor accident compensation claims, the deceased's age at the time of death is a crucial factor in determining the multiplier, which is used to calculate the total compensation. A higher multiplier signifies a longer period during which the claimant would have depended on the deceased's income, thereby increasing the compensation amount.

Notional Income

Notional income refers to the estimated income the deceased would have earned had the accident not occurred. This is calculated based on actual earnings at the time of the accident, adjusted for future prospects and personal expenses, and is a critical component in determining fair compensation.

Conclusion

The Supreme Court's decision in Saroj v. IFFCO-Tokio General Insurance Co. reinforces the necessity of relying on legally recognized documents for critical determinations such as age verification in compensation claims. By upholding the School Leaving Certificate over the Aadhar Card, the Court ensures that compensation calculations remain fair and grounded in statutory authority. This judgment not only rectifies the specific case at hand but also provides a clear legal direction for future cases involving similar disputes, thereby strengthening the framework of just compensation in motor accident tragedies.