The Madhya Pradesh High Court has held that an Aadhaar card cannot be treated as conclusive proof of a person's age, observing that the age recorded in a postmortem report may serve as a more reliable indicator based on medical assessment.
Justice Amit Seth made the observation while partly allowing an appeal filed by the parents of a 13-year-old boy who died in a motor accident in December 2019. The Court enhanced the compensation awarded to them from ₹5.45 lakh to ₹8,25,500.
In the said matter, the Motor Accident Claims Tribunal (MACT), Bhind, had determined the boy's age as 14 years, 7 months and 9 days based on his Aadhaar card.
However, the insurance company challenged this finding, relying on the postmortem report, which recorded the deceased's age as 13 years.
Accepting the insurance company's contention, the High Court observed that an Aadhaar card is primarily an identity document and cannot, by itself, conclusively establish the age of its holder.
"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 observed.
It further held that, in the circumstances of the case, the medical opinion recorded in the postmortem report provided a more reliable basis for determining the deceased's age.
The Court also examined the appropriate multiplier to be applied while calculating compensation. The insurance company contended that a multiplier of 15, rather than 18, should be applied since the deceased was below 15 years of age.
Opposing this argument, the parents relied on the Supreme Court's 2025 judgment in Ku Aarti v. Udayveer Singh, wherein a multiplier of 18 was applied in a case involving the death of a nine-year-old child.
However, relying on the Supreme Court's decision in Divya v. National Insurance Company Limited (2022), the High Court held that a multiplier of 15 was applicable in cases involving children below 15 years of age.
On the question of income, the Court accepted the parents' contention that the deceased's notional income should be assessed on the basis of minimum wages applicable to an unskilled worker. Accordingly, it fixed his monthly income at ₹7,950.
After deducting 50 per cent towards personal expenses and applying a multiplier of 15, the Court assessed the loss of dependency at ₹7,15,500.
It additionally awarded ₹40,000 each to the parents towards loss of parental consortium, ₹15,000 towards funeral expenses and ₹15,000 towards loss of estate.
Consequently, the total compensation was enhanced from ₹5.45 lakh to ₹8,25,500. The Court directed that the enhanced amount of ₹2,80,500 would carry interest at 6 per cent per annum from the date of filing of the original claim petition until realisation.
Advocate Dharmendra Rishishwar appeared for the parents, while Advocate Bal Krishna Agrawal represented the insurance company.
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