Case Background
In Saroj & Ors. vs. IFFCO-Tokio General Insurance Co., the claimants sought compensation after the death of a family member in a road accident. Initially, the Motor Accident Claims Tribunal (MACT) awarded compensation based on the age provided in the deceased’s School Leaving Certificate. However, the High Court later reduced the compensation by considering the age from the deceased’s Aadhaar card, leading the claimants to appeal to the Supreme Court.
Key Legal Questions
- Which Document Takes Precedence for Proof of Age? The main contention was between the Aadhaar card and the School Leaving Certificate for determining age. The difference in ages would significantly impact the final compensation.
- Fair Reduction of Compensation: The appeal also questioned whether the High Court’s reduction of compensation was legally justified.
Supreme Court's Decision
The Court ruled that the School Leaving Certificate should be prioritized over the Aadhaar card as proof of age. The reasoning relied on legal precedents and statutory regulations, including the Juvenile Justice (Care and Protection of Children) Act, 2015, which prioritizes certificates from schools and local authorities over Aadhaar data for determining age.
Key Points in Favor of the School Certificate:
- Statutory Preference: Under Section 94 of the Juvenile Justice Act, school certificates are preferred evidence.
- Aadhaar's Purpose: The Court noted that the Aadhaar system was primarily intended for unique identification and social benefit distribution, not as a comprehensive record of age. UIDAI guidelines also support this, stating that Aadhaar can verify identity but is not a standalone proof of birth date.
Related Case References
- K.S. Puttaswamy v. Union of India (2019): The Supreme Court underscored that Aadhaar’s primary purpose is identity verification, not age determination.
- Manoj Kumar Yadav v. State of M.P. (2023): The Madhya Pradesh High Court ruled against using Aadhaar for establishing age in juvenile cases.
- Navdeep Singh v. State of Punjab (2021): The Punjab & Haryana High Court ruled that Aadhaar was inadequate as proof of age in marriage-related cases under the Prohibition of Child Marriage Act, 2006.
Implications of This Ruling
- Establishing Age for Compensation Claims: The judgment impacts how age is determined in cases of insurance claims and compensation, ensuring higher precision when the exact age is in dispute.
- Wider Use in Legal Proceedings: The decision signals to courts that documents with statutory preference (such as school certificates) must be used over Aadhaar to avoid potential discrepancies.
Conclusion
This judgment reinforces that while Aadhaar is a powerful tool for identity, it does not replace traditional statutory documents for certain legal aspects, like age verification. By confirming the School Leaving Certificate's precedence, the Supreme Court supports a more consistent and statutory approach to age verification.