A) ABSTRACT / HEADNOTE

The case primarily dealt with the conflict between Aadhar Card and School Leaving Certificate as proof of the victim’s age, which directly impacted the calculation of compensation in a motor accident claim. The High Court erred by reducing the compensation awarded by the Motor Accident Claims Tribunal (MACT) on flawed grounds, relying on the date of birth mentioned in the Aadhar Card. The Supreme Court restored a more equitable compensation calculation based on the School Leaving Certificate, which holds statutory recognition under Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015 (JJ Act). The Court reaffirmed the principles governing just and reasonable compensation, emphasizing the non-conclusive nature of Aadhar Cards for age verification.

Keywords: Aadhar Card, School Leaving Certificate, Motor Accident Claims, Compensation, Multiplier Method, Proof of Age, Juvenile Justice Act, Notional Income, Future Prospects.

B) CASE DETAILS

i. Judgement Cause Title:
Saroj & Ors. v. IFFCO-TOKIO General Insurance Co. & Ors.

ii. Case Number:
Civil Appeal Nos. 12077-12078 of 2024

iii. Judgement Date:
24 October 2024

iv. Court:
Supreme Court of India

v. Quorum:
Justice Sanjay Karol and Justice Ujjal Bhuyan

vi. Author:
Justice Sanjay Karol

vii. Citation:
[2024] 10 S.C.R. 939 : 2024 INSC 816

viii. Legal Provisions Involved:

• Section 94(2) of the Juvenile Justice (Care and Protection of Children) Act, 2015
• Regulations under the Aadhaar (Enrolment and Update) Regulations, 2016
• Principles established in National Insurance Co. Ltd. v. Pranay Sethi [(2017) 16 SCC 680].

ix. Judgments Overruled by the Case (if any):
None explicitly overruled but criticized the High Court’s approach.

x. Case Related to Which Law Subjects:
Motor Accident Claims, Insurance Law, Procedural Law.

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

This case originated from a tragic road accident that led to the death of the victim, Silak Ram. His family sought compensation under the Motor Vehicle Act. While the Motor Accident Claims Tribunal awarded Rs. 19,35,400/- with interest, the High Court drastically reduced it to Rs. 9,22,336/-, citing discrepancies in age determination  between the Aadhar Card and School Leaving Certificate. The appellants challenged the reduction before the Supreme Court.

D) FACTS OF THE CASE

1. Accident and FIR: On August 4, 2015, the deceased was involved in a motorcycle accident, resulting in fatal injuries. The police registered FIR No. 481/2015 under Sections 279/337/304A of the Indian Penal Code.

2. Claim Petition: The deceased’s family (wife and children) filed Claim Petition No. 25/2015 before the MACT in Rohtak. The tribunal awarded Rs. 19,35,400/-.

3. High Court Reduction: On appeal, the High Court reduced compensation to Rs. 9,22,336/- on two grounds:

   • Age calculation based on the Aadhar Card (47 years), applying a multiplier of 13 instead of 14.
   • Income estimation based on minimum wages instead of special district rates.

4. Conflict of Evidence: The victim’s School Leaving Certificate stated his birthdate as October 7, 1970 (age 45 at the time of the accident), while the Aadhar Card indicated January 1, 1969.

5. Supreme Court Appeal: The family challenged the High Court’s decision, emphasizing errors in multiplier application and income calculation.

E) LEGAL ISSUES RAISED

1. Which document, the Aadhar Card or School Leaving Certificate, should be considered conclusive proof of age?

2. Was the High Court justified in reducing compensation based on minimum wage rates and a lower multiplier?

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Priority of School Certificate:
   The petitioners argued that the School Leaving Certificate, recognized under Section 94(2) of the Juvenile Justice Act, should take precedence over the Aadhar Card for determining the victim’s age.

2. Multiplier Application:
   Based on the victim’s age of 45 (School Certificate), a multiplier of 14 was applicable as per the Pranay Sethi guidelines.

3. Income Basis:
   They contended the deceased’s income should be calculated on district-specific rates, not minimum wages.

4. Interest Rate:
   The petitioners challenged the reduction of interest from 7.5% to 6% without reasoning.

G) RESPONDENT’S ARGUMENTS

1. Reliance on Aadhar Card:
   The respondents supported the High Court’s reliance on the Aadhar Card to calculate the victim’s age.

2. Uniform Wage Rates:
   They justified the use of state-level minimum wages for income calculation.

3. No Additional Burden:
   They argued against further enhancement, citing the award’s sufficiency.

H) JUDGEMENT

a. Ratio Decidendi

1. Primacy of School Certificate:
   The School Leaving Certificate was held as the authoritative document under Section 94(2) of the JJ Act, reinforced by various precedents and UIDAI Circular No. 08 of 2023. The Court ruled Aadhar Cards are not conclusive proof of age.

2. Multiplier Adjustment:
   Age recalibrated to 45 years (School Certificate), making a multiplier of 14 applicable.

3. Income Basis Reaffirmed:
   Tribunal’s reliance on special district rates was upheld due to evidence of the deceased’s agricultural and vehicular income.

4. Interest Enhancement:
   Interest rate restored to 8% to ensure just compensation.

b. Obiter Dicta

The Court emphasized the principle that compensation under MACT must be “just and reasonable,” underscoring the non-conclusive nature of Aadhar Cards.

c. Guidelines

1. Age Proof Hierarchy:

   • Priority to statutory documents (school certificates).
   • Avoid reliance on Aadhar for age determination.

2. Compensation Calculation:
   Apply accurate multipliers per victim’s age and Pranay Sethi principles.

3. Interest Rate Reasoning:
   Courts must justify deviations from standard interest rates.

I) CONCLUSION AND COMMENTS

The judgment reinforces the importance of statutory recognition of documents like School Certificates under the JJ Act. It emphasizes judicial consistency in compensation awards, ensuring fairness and adherence to established legal principles.

J) REFERENCES

1. National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680
2. UIDAI Circular No. 08 of 2023.
3. Manoj Kumar Yadav v. State of M.P. (2023 SCC OnLine MP 1919).
4. Shahrukh Khan v. State of M.P. (2023 SCC OnLine MP 2740).
5. Navdeep Singh v. State of Punjab (2021 SCC OnLine P&H 4553).