Aadhaar card not conclusive proof of age; postmortem report more reliable: Madhya Pradesh High Court

The Madhya Pradesh High Court recently held that an Aadhaar card cannot be treated as conclusive proof of a person's age, observing that that a postmortem report is a more reliable indicator [Rajesh Singh & Anr. v Rahul Singh & Ors.].

Justice Amit Seth made the observation while enhancing the compensation awarded to the parents of a 13-year-old boy who died in a motor accident in December 2019.

A Motor Accidents Claims Tribunal had earlier relied on the boy's Aadhaar card to determine his age to be 14 years old. The insurance company, on the other hand, pointed to the postmortem report which recorded him as 13 years old.

The Court found merit in the insurance company's argument and observed that an Aadhaar card cannot, by itself, establish the age of its holder conclusively.

"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," said the Court.

The Court held that the medical assessment in the postmortem report was a more reliable basis for determining the deceased's age.

"In the facts and circumstances of the present case, this Court finds the medical opinion recorded in the postmortem report to be a more reliable basis for determining the age of the deceased," held the Court.

The Court was hearing an appeal filed by the boy's parents. They sought enhancement of the ₹5.45 lakh compensation awarded by the Motor Accident Claims Tribunal (MACT), Bhind, in September 2022.

The tribunal had determined the boy's age as 14 years, 7 months and 9 days on the basis of his Aadhaar card. However, the insurance company challenged this finding, pointing out that the postmortem report recorded his age as 13 years.

The Court also considered the multiplier to be applied while calculating compensation. The insurance company argued that a multiplier of 15, instead of 18, should apply since the boy was below 15 years of age.

The parents opposed this, relying on a 2025 Supreme Court judgment in Ku Aarti v. Udayveer Singh (2025), in which 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 must be applied for children below 15 years of age.

The Court also accepted the parents' argument that the boy's notional income should be calculated on the basis of minimum wages for an unskilled worker. It fixed his monthly income at ₹7,950.

After deducting 50 per cent 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, ₹15,000 towards funeral expenses and ₹15,000 towards loss of estate.

The total compensation was enhanced from ₹5.45 lakh to ₹8,25,500 and the parents' appeal was partly allowed on these terms.

The Court also directed that the enhanced compensation of ₹2,80,500 would carry interest at 6 per cent per annum from the date of filing of the original claim petition until its realisation.

Advocate Dharmendra Rishishwar appeared for the parents.

Advocate Bal Krishna Agrawal represented the insurance company.

[Read Order]