The Madhya Pradesh High Court held that Aadhaar and voter ID cards cannot serve as conclusive proof of date of birth in job matters. Justice Jai Kumar Pillai said service records maintained from the start of employment are generally more reliable.
The Madhya Pradesh High Court clarified that Aadhaar and voter ID cards do not qualify as definitive proof of date of birth in employment-related matters.
Justice Jai Kumar Pillai remarked that service records established when an employee joins their position and relied upon throughout their career are usually regarded as trustworthy.
The Court specified that such records cannot be substituted with identity documents like Aadhaar and voter ID cards, which are issued significantly later.
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The Court emphasized,
“The Aadhaar Card and Voter Identity Card relied upon by Respondent No.5 (Hirlibai) cannot be treated as determinative proof of her date of birth. These documents are prepared on the basis of self-declaration and are meant for identification purposes alone. They are neither primary evidence nor statutory proof for determination of age in service matters,”
This ruling arose from a petition submitted by Pramila, who was appointed as an Anganwadi Sahayika (Helper) in June 2018, following a formal selection process.
This appointment occurred after the retirement of the previous Anganwadi worker, Hirlibai, in March 2017, based on her officially recorded date of birth.
Although Hirlibai did not contest her retirement at the time, she appealed to the appellate authority nearly two years later. She claimed that her recorded date of birth was incorrect and presented her Aadhaar and voter ID cards, which indicated her birthdate as January 1, 1964 almost nine years later than what was documented in her service records.
The appellate authority approved her appeal in September 2020, resulting in her reinstatement and the termination of Pramila’s position. Subsequently, Pramila approached the High Court.
The High Court noted that the date of birth on Hirlibai’s Aadhaar card lacked any supporting documentation. It remarked that the date of birth listed was likely an estimated entry used when adequate proof is unavailable, and thus could not supersede official service records.
Additionally, the Court observed facts that contradicted Hirlibai’s assertion of a later birth date, including her children’s recorded birth years, all of which preceded the year she claimed as her own.
The Court said,
“These undisputed facts clearly negate the possibility of Respondent No.5 (Hirlibai) having been born in the year 1964,”
The Court also pointed out significant procedural errors regarding the removal of Pramila from service. It stated that Pramila, appointed through a legitimate selection process, was not included as a party in the appeal and was not given an opportunity to be heard, even though the appellate authority was aware that her position was already filled.
The Court stated,
“No independent notice of termination was issued, no inquiry was conducted, and no reasons were assigned before terminating the services of the petitioner. The petitioner was removed merely as a collateral consequence of the appellate order, which itself is legally flawed. Such a method of termination not only violates the principles of natural justice but also runs contrary to the departmental guidelines governing removal of Anganwadi Workers,”
The appellate order was found to be flawed due to delays, inappropriate reliance on inadmissible documents, and violation of natural justice standards.
Consequently, the High Court cancelled both the 2020 appellate order and the subsequent termination of Pramila, ordering her reinstatement with full service and benefits.
The Court also directed that any salary or benefits paid to the retired employee after her retirement be recovered, with interest, and returned to the State.
Advocate Akshay Bhonde represented Pramila, while Advocate SP Pandey appeared for Hirlibai. Government Advocate Amit Bhatia represented the State and other respondents.
Case Title: Pramila v. State of Madhya Pradesh & Ors.
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