Aadhaar Card Not Conclusive Proof of Age, Postmortem Report More Reliable

Source: Madhya Pradesh High Court

Why in News? 

Justice Amit Seth of the Madhya Pradesh High Court decided Rajesh Singh v. Rahul Singh (2026). The Court partly allowed an appeal for enhanced compensation for the death of a minor in a motor vehicle accident. 

The Court also held: 

• An Aadhaar card is primarily an identity document. It is not conclusive proof of age. 
• The age in the postmortem report, based on a medical assessment, is a more reliable basis for fixing the deceased’s age. 
• The notional income of a deceased minor should be assessed on the basis of the minimum wages payable to an unskilled workman on the date of the accident.

What was the Background of the Rajesh Singh v. Rahul Singh (2026) Case? 

• The accident: A minor died in a motor vehicle accident on 24 December 2019. 
• Tribunal’s award: The Motor Accident Claims Tribunal awarded ₹5,45,000 with interest at 6% a year. 
• The appeal: The appellants filed a miscellaneous appeal under Section 173 of the Motor Vehicles Act, 1988 for enhanced compensation. 

What the appellants argued: 

• The deceased was a minor, and the Tribunal had taken his notional income at ₹25,000. 
• The notional income should have been fixed on the basis of minimum wages for a person with the same qualifications, that is, ₹7,950 a month. 

What the Insurance Company argued: 

• The appellants raised the valuation of the appeal from ₹3 lakh to ₹8 lakh and paid court fees for this on 12 October 2026. 
• So if any enhancement is allowed, interest should be computed from the date the enhanced court fees were paid. 

Questions before the High Court: 

• How should the notional income of a deceased minor be assessed? 
• Should the deceased’s age be taken from the Aadhaar card or from the postmortem report? 
• What multiplier applies?

What were the Court’s Observations? 

On notional income: 

• The notional income of the deceased should have been assessed on the basis of the minimum wages payable to an unskilled workman on the date of the accident. 
• Under the Madhya Pradesh State Legal Services Authority (MPSLSA) Guidelines, the monthly income is taken as ₹7,950, which makes the annual income ₹95,400. 

On proof of age: 

• The Tribunal had taken the deceased’s age from the Aadhaar card as 14 years, 7 months and 9 days. 
• The postmortem report recorded his age as 13 years. 
• An Aadhaar card is primarily an identity document, and cannot by itself be conclusive proof of the holder’s age. 
• The age in the postmortem report is based on a medical assessment made during the postmortem examination. 
• On the facts of the case, the medical opinion in the postmortem report was the more reliable basis. 
• The deceased’s age was therefore taken as 13 years at the time of the accident. 

On the multiplier: 

• Following Divya v. National Insurance Company Ltd., the appropriate multiplier was 15, not 18 as the Tribunal had applied.

Decision 

• An Aadhaar card is not conclusive proof of age. The age in the postmortem report was preferred. 
• Notional income was fixed at ₹7,950 a month (₹95,400 a year), on the basis of minimum wages. 
• A multiplier of 15 was applied. 
• The total compensation was raised to ₹8,25,500, against the ₹5,45,000 awarded by the Tribunal. 
• The appeal was partly allowed.

What is the Legal Position on Aadhaar as Proof of Age? 

• Aadhaar Act, 2016: Aadhaar is a proof of identity. Under Section 9, it is not by itself proof of citizenship or domicile. 
• Date of birth in Aadhaar: It is usually recorded on the basis of documents the applicant produces, or on self-declaration. 
• Supreme Court position: In Saroj v. IFFCO-Tokio General Insurance Co. (2024), the Supreme Court held that Aadhaar cannot be relied on to determine age in motor accident claims. It preferred the school leaving certificate, which has statutory recognition under Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015. 
• UIDAI’s stand: UIDAI has itself clarified that Aadhaar is a proof of identity and not proof of date of birth. 

What are the Relevant Provisions of the Motor Vehicles Act, 1988? 

Section 166 – Application for compensation: 

• A claim for compensation arising from a motor accident can be filed before the Motor Accident Claims Tribunal. 
• It can be filed by the injured person, the owner of the property, or the legal representatives of the deceased. 

Section 173 – Appeals: 

• Any person aggrieved by a Tribunal’s award may appeal to the High Court within 90 days. 
• The High Court may entertain an appeal after 90 days if there is sufficient cause for the delay. 
• No appeal lies if the amount in dispute is less than ₹1 lakh.