Supreme Court Overturns High Court’s Decision on Compensation Calculation in Motor Accident Case
In a significant ruling, the Supreme Court has set aside a decision made by the Punjab and Haryana High Court regarding the calculation of compensation for a victim of a motor accident case, specifically in the case of Saroj and Others v. IFFCO-Tokio General Insurance Company and Others.
The Bench, consisting of Justices Sanjay Karol and Ujjal Bhuyan, determined that the age of the deceased should be conclusively derived from the date of birth listed in the school leaving certificate, rather than the date of birth recorded on the Aadhaar card. The court emphasized that the date of birth in the school leaving certificate has statutory recognition under Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015.
The case revolved around discrepancies between the dates of birth provided by the victim’s school leaving certificate and Aadhaar card, which impacted the computation of compensation. Initially, the Motor Accidents Claim Tribunal (MACT) awarded ₹19,35,400 to the legal representatives of the deceased. However, the High Court later reduced this amount to ₹9,22,336, arguing that the MACT had applied the age multiplier incorrectly in its calculations.
The High Court had calculated the deceased’s age as 47 years based on the information from the Aadhaar card, applying a multiplier of 13. In contrast, the legal representatives contended that the age derived from the school leaving certificate was 45 years, thus advocating for a multiplier of 14.
The apex court sided with the legal representatives, noting High Court judgments that regard the Aadhaar card as less than definitive proof of age. It pointed out that the Unique Identification Authority of India (UIDAI) clarified in a 2023 circular that an Aadhaar card can establish identity but is not inherently proof of date of birth.
“We may clarify that we have not expressed any view on the merits of these cases before their respective High Courts, and reference has only been made to them for the limited purpose of examining the suitability of the Aadhaar Card as proof of age. That being the position, as it stands with respect to the determination of age, we have no hesitation in accepting the contention of the claimant-appellants, based on the School Leaving Certificate,” the Court remarked.
Consequently, the Supreme Court revised the compensation amount to ₹15 lakh, applying the multiplier of 14 and factoring in future prospects at 25 percent.
In this case, advocates Srishti Choudhary, Shefali Choudhary, and Namita Choudhary represented Saroj and others, while a team of advocates including Shivam Singh, Manish Kumar, and others appeared for IFFCO-Tokio General Insurance Company, with additional representation for other respondents.
