Supreme Court Upholds MACT Award, Prioritizes School Certificate for Age Proof in Accident Claim: Saroj & Ors. vs. IFFCO-Tokio General Insurance Co. & Ors. (24 October 2024)

LEGAL ISSUE: Determination of authoritative document for age proof in motor accident claims.
CASE TYPE: Motor Accident Compensation
Case Name: Saroj & Ors. vs. IFFCO-Tokio General Insurance Co. & Ors.
Judgment Date: 24 October 2024

Date of the Judgment: 24th October, 2024
Citation: 2024 INSC 816
Judges: Sanjay Karol J., Ujjal Bhuyan J.
Can an Aadhar card be considered conclusive proof of age in motor accident compensation claims? The Supreme Court of India recently addressed this question, clarifying the hierarchy of documents for age verification. This judgment emphasizes the importance of the School Leaving Certificate over the Aadhar card for determining age in such cases. The bench, comprising Justices Sanjay Karol and Ujjal Bhuyan, delivered the judgment.

Case Background

On August 4, 2015, Silak Ram was fatally injured in a road accident while traveling on a motorcycle with Rohit. Both were found injured on the side of the road. Silak Ram succumbed to his injuries, while Rohit was taken to the hospital. The incident was reported to the police by Krishan, who found them. During the investigation, Rohit’s statement revealed details of the offending vehicle, leading to the registration of F.I.R. No. 481/2015 under Sections 279, 337, and 304A of the Indian Penal Code, 1860.

The family members of the deceased, the claimant-appellants, filed a claim petition before the Motor Accident Claims Tribunal (MACT), Rohtak, on December 16, 2015, seeking compensation for the death of Silak Ram. The MACT awarded Rs. 19,35,400 with 7.5% interest. However, on appeal, the High Court reduced the compensation to Rs. 9,22,336, leading the claimant-appellants to approach the Supreme Court.

Timeline:

Course of Proceedings

The Motor Accident Claims Tribunal (MACT) initially awarded a compensation of Rs. 19,35,400 with an interest rate of 7.5% per annum. The High Court, on appeal, reduced the compensation to Rs. 9,22,336, citing the use of minimum wage rates applicable throughout the state instead of the special DC rates of the district, and also revised the age of the deceased based on the Aadhar Card, which affected the multiplier. Aggrieved by this reduction, the claimant-appellants appealed to the Supreme Court.

Legal Framework

The Supreme Court referred to Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015, which outlines the process for age determination. This section gives primacy to the date of birth certificate from the school, or the matriculation or equivalent certificate from the concerned examination Board. The court also discussed the purpose of the Aadhar scheme as established in the judgment of K.S. Puttaswamy v. Union of India [(2019) 1 SCC 1], noting that it is primarily for establishing identity and not as conclusive proof of date of birth.

“(2) In case, the Committee or the Board has reasonable grounds for doubt regarding whether the person brought before it is a child or not, the Committee or the Board, as the case may be, shall undertake the process of age determination, by seeking evidence by obtaining — (i) the date of birth certificate from the school, or the matriculation or equivalent certificate from the concerned examination Board, if available; and in the absence thereof; (ii) the birth certificate given by a corporation or a municipal authority or a panchayat; (iii) and only in the absence of (i) and (ii) above, age shall be determined by an ossification test or any other latest medical age determination test conducted on the orders of the Committee or the Board…”

Arguments

The claimant-appellants argued that the High Court erred in reducing the compensation. They contended that the multiplier should be 14, based on the School Leaving Certificate, which recorded the deceased’s date of birth as 7th October, 1970, making him 45 years old at the time of the accident. They also argued that the MACT’s calculation of monthly income was correct, as the deceased was an agriculturist owning a tractor and a JCB machine. The claimant-appellants relied on the School Leaving Certificate as primary proof of age.

The respondents, on the other hand, supported the High Court’s decision, arguing that the Aadhar card, which recorded the deceased’s date of birth as 1st January, 1969, should be considered valid and that the minimum wage rates were a better measure for calculating the notional income of the deceased. They argued that the Aadhar card was a reliable document for determining age.

Innovativeness of the argument: The claimant-appellants innovatively argued that the School Leaving Certificate should be given primacy over the Aadhar card for determining age in accident compensation claims, aligning with the statutory recognition given to such certificates under the Juvenile Justice Act, 2015.

Issues Framed by the Supreme Court

The Supreme Court framed the following issues for consideration:

1. In case of conflict of the dates of birth between the two documents, as in this case between the School Leaving Certificate and the Aadhar Card, which of the two is to be taken as authoritative?
2. Whether in the facts of the case, the High Court’s reduction of the compensation awarded by the learned MACT, was justified and in accordance with law?

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court considered the following authorities:

1. K.S. Puttaswamy v. Union of India [(2019) 1 SCC 1] – Supreme Court of India: The court referred to this case to understand the purpose of the Aadhar scheme, noting it is primarily for establishing identity and not as conclusive proof of date of birth.
2. Manoj Kumar Yadav v. State of M.P. [2023 SCC OnLine MP 1919] – Madhya Pradesh High Court: This case held that the age mentioned in the Aadhar Card could not be taken as conclusive proof of age under Section 94 of the JJ Act.
3. Shahrukh Khan v. State of M.P. [2023 SCC OnLine MP 2740] – Madhya Pradesh High Court: This case held that if the genuineness of the School Leaving Certificate is not under challenge, the said document has to be given due primacy.
4. Navdeep Singh & Anr. v. State of Punjab & Ors. [2021 SCC OnLine P&H 4553] – Punjab & Haryana High Court: This case held that Aadhar Cards were not “firm proof of age” in the context of the Prohibition of Child Marriage Act, 2006.
5. Noor Nadia & Anr. v. State of Punjab & Ors. [2021 SCC OnLine P&H 1514] – Punjab & Haryana High Court: Similar observations were made regarding Aadhar cards not being firm proof of age.
6. Muskan v. State of Punjab [2021 SCC OnLine P&H 3649] – Punjab & Haryana High Court: Similar observations were made regarding Aadhar cards not being firm proof of age.
7. Parvati Kumari v. State of U.P. [2019 SCC OnLine All 7085] – High Court of Judicature of Allahabad: This case aligned with the view that Aadhar cards are not conclusive proof of age.
8. Kumit Kumar v. State of H.P. [2024 SCC OnLine HP 2965] – Himachal Pradesh High Court: This case aligned with the view that Aadhar cards are not conclusive proof of age.
9. Sofikul Islam v. State of Kerala [2022 SCC OnLine Ker 5814] – High Court of Kerala: This case aligned with the view that Aadhar cards are not conclusive proof of age.
10. State of Maharashtra v. Unique Identification Authority of India And Ors. [Criminal Writ Petition No. 3002 of 2022] – Bombay High Court: The court took note of the office memorandum dated 20th December, 2018, stating that an Aadhar number can be used for establishing identity but is not per se proof of date of birth.
11. Gopalbhai Naranbhai Vaghela v. Union Of India & Anr. [Order dated 26th February, 2024 passed in R/ Civil Special Application No. 16484 of 2022] – Gujarat High Court: This case directed the release of the petitioner’s pension in accordance with the date mentioned in the School Leaving Certificate, disregarding the Aadhar card.
12. Shabana v. NCT of Delhi [2024 SCC OnLine Del 5058] – Delhi High Court: The court recorded a statement from UIDAI that “Aadhar Card may not be used as proof of date of birth.”
13. Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015: The Court relied on this provision which provides that the school certificate is the primary document for age determination.
14. National Insurance Co. Ltd. v. Pranay Sethi [(2017) 16 SCC 680] – Supreme Court of India: The court relied on this case to determine the principles for calculating compensation in motor accident claims.

Judgment

How each authority was viewed by the Court?

✓ K.S. Puttaswamy v. Union of India [(2019) 1 SCC 1]*: The Court used this to understand the purpose of the Aadhar scheme, emphasizing that it is primarily for establishing identity and not as conclusive proof of date of birth.

✓ Manoj Kumar Yadav v. State of M.P. [2023 SCC OnLine MP 1919]*: The Court aligned with this judgment, which held that the age mentioned in the Aadhar Card could not be taken as conclusive proof of age under Section 94 of the JJ Act.

✓ Shahrukh Khan v. State of M.P. [2023 SCC OnLine MP 2740]*: The Court aligned with this judgment, which held that if the genuineness of the School Leaving Certificate is not under challenge, the said document has to be given due primacy.

✓ Navdeep Singh & Anr. v. State of Punjab & Ors. [2021 SCC OnLine P&H 4553]*: The Court aligned with this judgment, which held that Aadhar Cards were not “firm proof of age”.

✓ Noor Nadia & Anr. v. State of Punjab & Ors. [2021 SCC OnLine P&H 1514]*: The Court aligned with this judgment, which made similar observations regarding Aadhar cards not being firm proof of age.

✓ Muskan v. State of Punjab [2021 SCC OnLine P&H 3649]*: The Court aligned with this judgment, which made similar observations regarding Aadhar cards not being firm proof of age.

✓ Parvati Kumari v. State of U.P. [2019 SCC OnLine All 7085]*: The Court aligned with this judgment, which held that Aadhar cards are not conclusive proof of age.

✓ Kumit Kumar v. State of H.P. [2024 SCC OnLine HP 2965]*: The Court aligned with this judgment, which held that Aadhar cards are not conclusive proof of age.

✓ Sofikul Islam v. State of Kerala [2022 SCC OnLine Ker 5814]*: The Court aligned with this judgment, which held that Aadhar cards are not conclusive proof of age.

✓ State of Maharashtra v. Unique Identification Authority of India And Ors. [Criminal Writ Petition No. 3002 of 2022]*: The Court took note of the office memorandum dated 20th December, 2018, stating that an Aadhar number can be used for establishing identity but is not per se proof of date of birth.

✓ Gopalbhai Naranbhai Vaghela v. Union Of India & Anr. [Order dated 26th February, 2024 passed in R/ Civil Special Application No. 16484 of 2022]*: The Court aligned with this judgment, which directed the release of the petitioner’s pension in accordance with the date mentioned in the School Leaving Certificate, disregarding the Aadhar card.

✓ Shabana v. NCT of Delhi [2024 SCC OnLine Del 5058]*: The Court aligned with this judgment, which recorded a statement from UIDAI that “Aadhar Card may not be used as proof of date of birth.”

✓ Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015: The Court relied on this provision, which provides that the school certificate is the primary document for age determination.

✓ National Insurance Co. Ltd. v. Pranay Sethi [(2017) 16 SCC 680]*: The Court relied on this case to determine the principles for calculating compensation in motor accident claims.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the statutory recognition given to the School Leaving Certificate under Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015. The Court also considered the purpose of the Aadhar scheme, which is to establish identity, not to serve as proof of date of birth. The Court emphasized that the High Court should not have substituted its view for that of the MACT without sufficient reason. The Court also noted that the compensation awarded in such cases must be just and reasonable, considering the loss suffered by the claimants.

The Court’s reasoning was based on a combination of legal principles and factual considerations. The primary focus was on the legal framework that prioritizes the School Leaving Certificate for age determination, which is reflected in the higher percentage given to law. The factual aspects of the case, such as the conflicting documents and the MACT’s findings, were also considered but were secondary to the legal analysis.

The Court’s reasoning was that the School Leaving Certificate has statutory recognition under Section 94(2) of the Juvenile Justice Act, 2015, which makes it the primary document for age determination. The Court also noted that the Aadhar card is not a proof of date of birth, as it is primarily for establishing identity. The Court also emphasized that the High Court should not have substituted its view for that of the MACT without sufficient reason.

The Court considered the alternative interpretation that the Aadhar card could be used as proof of age, but rejected it based on the statutory provisions of the JJ Act and the purpose of the Aadhar scheme. The final decision was reached by prioritizing the School Leaving Certificate and reinstating the MACT’s award, with an enhanced interest rate.

“The general rule insofar as appellate proceedings are concerned is that a Court sitting in appeal is not to substitute its view for that of the Court below. It is only to see that the decision arrived at is not afflicted by perversity, illegality or any other such vice which may compromise it beyond redemption.”

“It is also well settled that an order is not to be interfered with simply because another view is possible, which, in the impugned order the High Court seems to have done.”

“An Aadhaar number can be used for establishing identity of an individual subject to authentication and thereby, per se its not a proof of date of birth”

The Supreme Court did not have a dissenting opinion in this case. The bench was unanimous in its decision.

The implications for future cases are that the School Leaving Certificate will be given primacy over the Aadhar card for age determination in cases related to motor accident claims. This decision clarifies the hierarchy of documents for age verification and ensures that the statutory provisions of the JJ Act are followed.

The Court did not introduce any new doctrines or legal principles but reaffirmed the existing legal framework and its application to the facts of the case. The Court emphasized the importance of following the statutory provisions and not substituting its view for that of the lower court without sufficient reason.

Key Takeaways

• ✓ School Leaving Certificates are primary documents for age proof in motor accident claims.
• ✓ Aadhar cards are not conclusive proof of date of birth.
• ✓ Appellate courts should not substitute their view for that of lower courts without valid reasons.
• ✓ Compensation awarded by MACT should be just and reasonable.
• ✓ Interest rate on compensation should be fair and adequate.

Directions

The Supreme Court directed that the notional income should be taken as Rs. 9,000, the date of birth as 7th October 1970, and the multiplier as 14. The total compensation payable is Rs. 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.

Development of Law

The ratio decidendi of the case is that the School Leaving Certificate is the primary document for determining age in motor accident claims, and the Aadhar card is not a conclusive proof of age. This decision reinforces the statutory recognition given to school certificates under the Juvenile Justice Act, 2015. There is no change in the previous position of law, but the judgment clarifies the application of existing legal principles in the context of conflicting documents for age proof.

Conclusion

The Supreme Court allowed the appeals, setting aside the High Court’s decision. The Court emphasized that the School Leaving Certificate is the primary document for determining age in motor accident claims and that the Aadhar card is not a conclusive proof of age. The Court also held that the High Court should not have substituted its view for that of the MACT without sufficient reason. The compensation was enhanced to Rs. 15,00,000 with 8% interest from the date of filing of the claim petition.

Category

Parent Category: Motor Accident Claims

Child Category: Age Determination in Motor Accident Claims

Child Category: School Leaving Certificate

Child Category: Aadhar Card

Child Category: Compensation

Parent Category: Juvenile Justice (Care and Protection of Children) Act, 2015

Child Category: Section 94(2), Juvenile Justice (Care and Protection of Children) Act, 2015

FAQ

Q: What is the main issue addressed in this Supreme Court judgment?

A: The main issue is determining which document is authoritative for age proof in motor accident compensation claims when there is a conflict between the School Leaving Certificate and the Aadhar card.

Q: What did the Supreme Court decide about the use of the School Leaving Certificate?

A: The Supreme Court held that the School Leaving Certificate is the primary document for determining age in motor accident claims, given its statutory recognition under Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015.

Q: Is the Aadhar card considered a valid proof of date of birth according to this judgment?

A: No, the Supreme Court clarified that the Aadhar card is primarily for establishing identity and is not a conclusive proof of date of birth.

Q: How does this judgment affect future motor accident claims?

A: In future motor accident claims, the School Leaving Certificate will be given primacy over the Aadhar card for age determination.

Q: What was the final compensation awarded by the Supreme Court?

A: The Supreme Court awarded a total compensation of Rs. 15,00,000 with 8% interest from the date of filing of the claim petition.