Aadhaar Not Conclusive Proof Of Age, the Madhya Pradesh High Court has held, taking a deceased boy’s age from his postmortem report and raising his parents’ motor accident compensation from Rs 5,45,000 to Rs 8,25,500.
Gwalior: A boy’s Aadhaar card said he was past 14; the postmortem report said 13. The Madhya Pradesh High Court at Gwalior went with the report, ruling that Aadhaar Not Conclusive Proof Of Age because it is primarily an identity document, in a motor accident claim arising from the death of the minor [Rajesh Singh and Another v. Rahul Singh and Others].
Justice Amit Seth passed the order on November 3, 2026, partly allowing the parents’ appeal and raising the compensation from Rs 5,45,000 to Rs 8,25,500.
Identity document, not age proof
The Motor Accident Claims Tribunal, Bhind, had fixed the boy’s age at 14 years, 7 months and 9 days from the Aadhaar card. The insurance company, through cross-objections under Order XLI Rule 22 CPC, pointed to the postmortem report (Ex. P10), a scientific report, which recorded the age as 13 years. The High Court accepted that objection:
“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. Therefore, 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.”
The deceased was therefore taken to be 13 years old at the time of the accident.
What the parents and the insurer argued
The boy died in a road accident on December 24, 2019. His parents, Rajesh Singh and another, appealed under Section 173 of the Motor Vehicles Act, 1988 against the Tribunal’s award of September 14, 2022 in Claim Case No. 43 of 2020. Negligence and liability were not in dispute, and the appeal was confined to the quantum.
Appearing for the parents, Dharmendra Rishishwar argued that the Tribunal ought to have taken the child’s notional income at the minimum wages for an unskilled worker on the date of the accident, Rs 7,950 a month. For the insurance company, Bal Krishna Agrawal said, besides the age point, that the multiplier should be 15 and not 18.
Fifteen, not eighteen
The parents relied on the Supreme Court’s order in Ku. Aarti v. Udayveer Singh, where a multiplier of 18 was applied for a nine-year-old, and on a coordinate bench ruling following it. Justice Seth chose a different line. He followed the Supreme Court’s reasoning in Divya v. National Insurance Company Limited, which relied on the three-judge bench decision in Reshma Kumari to hold that the multiplier for victims up to 15 years is 15. The High Court held:
“In view of the aforesaid legal position, this Court is of the considered opinion that, having regard to the age of the deceased, which was below 15 years at the time of the accident, the appropriate multiplier to be applied in the present case is 15 and not 18, as applied by the learned Claims Tribunal.”
The recalculation
Applying the Madhya Pradesh State Legal Services Authority guidelines, the Court took the monthly income at Rs 7,950, or Rs 95,400 a year, deducted 50% for personal expenses and applied the multiplier of 15, reaching Rs 7,15,500 for loss of dependency. To this it added Rs 40,000 to each parent for loss of parental consortium, Rs 15,000 for funeral expenses and Rs 15,000 for loss of estate, which the Tribunal had not awarded. The total came to Rs 8,25,500, an enhancement of Rs 2,80,500.
One more objection from the insurer failed. After the parents raised the appeal’s valuation from Rs 3 lakh to Rs 8 lakh and paid enhanced court fees, the insurer wanted interest on any enhancement to run only from the date of that payment. The Court noted that the enhancement fell within the original valuation and directed that the entire enhanced sum carry interest at the Tribunal’s rate of 6% a year from the date of the claim petition until realisation. The cross-objections were allowed only on age and multiplier.
Why the judgment matters
Aadhaar is often the most readily available document in accident claims, and Tribunals frequently use it to fix the victim’s age, which in turn decides the multiplier. The ruling makes clear that Aadhaar proves identity, not age, and that where a medical assessment such as a postmortem report is on record, it can carry greater weight.
The order also shows that a lower age does not always mean a lower award. Even with the multiplier reduced, correcting the notional income to minimum wages and adding the heads the Tribunal had missed left the parents with a higher sum. It also adds to the line of High Court decisions applying a multiplier of 15 for child victims, despite conflicting Supreme Court orders on the point.
Case Title: Rajesh Singh and Another v. Rahul Singh and Others [Misc. Appeal No. 6071 of 2022]
Neutral Citation: 2026:MPHC-GWL:33646
Bench: Justice Amit Seth, Madhya Pradesh High Court (Gwalior Bench)
Date of Order: November 3, 2026
Counsel for Appellants-Claimants: Dharmendra Rishishwar
Counsel for Respondent No. 3 (Insurance Company): Bal Krishna Agrawal