‘Aadhaar not conclusive proof of age’: Madhya Pradesh HC highlights significance of postmortem report in accident claims

The Madhya Pradesh High Court has ruled that an Aadhaar card cannot be treated as conclusive proof of age in motor accident compensation cases, holding that a postmortem report’s medical assessment is a more reliable basis for determining a deceased victim’s age. Justice Amit Seth observed while deciding a compensation appeal arising from a fatal road accident.

The case, Rajesh Singh and Another v. Rahul Singh and Others (Misc. Appeal No. 6071 of 2022), concerned the death of a minor, Harendra Singh Baghel, in an accident on 24 December, 2019. The Motor Accident Claims Tribunal, Bhind, had awarded ₹5.45 lakh to the parents based on the age recorded in the deceased’s Aadhaar card, which showed him to be 14 years, 7 months, and 9 days old. The insurance company challenged this in cross-objections, arguing that the postmortem report recorded the deceased’s age as 13 years and that the Aadhaar card was not conclusive proof of age.

Accepting the insurer’s contention, the High Court observed: “An Aadhaar Card is primarily an identity document and cannot, by itself, be treated as conclusive proof of the age of its holder. On the other hand, the age recorded in the postmortem report is based upon medical assessment conducted in the course of postmortem examination”. The Court accordingly determined the deceased’s age as 13 years.

The age determination had a direct bearing on the multiplier applied for calculating compensation. The Tribunal had applied a multiplier of 18, but the High Court held that a multiplier of 15 was appropriate for a deceased below 15 years of age, relying on the Supreme Court’s previous decisions.

Assessing the deceased’s notional monthly income at ₹7,950 based on the minimum wages for an unskilled worker, deducting 50% towards personal expenses, and applying the multiplier of 15, the Court calculated the loss of dependency at ₹7,15,500. It further awarded ₹40,000 each to the parents towards loss of parental consortium, along with ₹15,000 each for funeral expenses and loss of estate.

The total compensation was recalculated at ₹8,25,500, resulting in an enhancement of ₹2,80,500 over the Tribunal’s award. The enhanced amount will carry interest at 6% per annum from the date of filing the claim petition. The Court partly allowed the parents’ appeal and also allowed the insurance company’s cross-objections to the extent of correcting the deceased’s age and applying the appropriate multiplier.

The ruling clarified the evidentiary distinction between identity documents and medical evidence in accident claims, and is expected to guide tribunals when Aadhaar-based age records conflict with postmortem findings.