In a significant ruling impacting compensation claims under motor accident laws, the Supreme Court of India, led by Justice Sanjay Karol and Justice Ujjal Bhuyan, emphasized that the School Leaving Certificate should be regarded as the authoritative document for determining the age of a deceased claimant, superseding the Aadhaar Card. In the case of Saroj & Ors. vs. IFFCO-Tokio General Insurance Co. & Ors., the Court underlined that the Aadhaar card, while essential for identity verification, cannot be considered conclusive proof of age. The decision not only affects the present case but sets a precedent for future disputes where conflicting documents are presented to establish the age of a claimant or deceased in compensation cases.
Background of the Case
The case originates from a fatal road accident that occurred on August 4, 2015, near Rohtak, Haryana. The victim, Silak Ram, was riding a motorcycle along with another person when both were discovered injured on the roadside. Silak Ram later succumbed to his injuries, leaving behind his wife, Saroj, and their two sons.
Following the accident, Saroj and her sons filed a claim for compensation before the Motor Accident Claims Tribunal (MACT), Rohtak, seeking damages for the death of Silak Ram. The MACT, in its order dated April 26, 2017, awarded the family a sum of Rs. 19,35,400 with an interest of 7.5% from the date of filing the petition. The Tribunal based its calculation on the notional income of the deceased and applied a multiplier of 14, considering his age as per the School Leaving Certificate, which listed his birth date as October 7, 1970.
However, the insurance company, IFFCO-Tokio General Insurance Co., challenged the award in the Punjab and Haryana High Court, arguing that the calculation should consider the birth date on the Aadhaar Card (January 1, 1969), which would reduce the multiplier to 13. Additionally, the High Court revised the notional income and reduced the compensation to Rs. 9,22,336, reasoning that the minimum wage rates issued by the government should be used instead of district-specific rates. Dissatisfied with this reduction, Saroj and her sons approached the Supreme Court.
Legal Issues Involved
The Supreme Court was called upon to adjudicate the following key issues:
1. Authority of Documents for Age Determination:
– The central issue was whether the School Leaving Certificate or the Aadhaar Card should be the authoritative document for determining the age of the deceased in compensation cases. This determination impacts the multiplier used in calculating the compensation amount, which directly affects the total compensation awarded to the claimant.
2. Calculation of Compensation:
– The Supreme Court had to examine whether the High Court was justified in reducing the compensation by altering the multiplier and notional income calculated by the MACT. This involved assessing if the appellate court’s interpretation aligned with the established principles of fair compensation for victims of road accidents.
3. Rate of Interest:
– The appellants also challenged the reduction in the rate of interest from 7.5% to 6%, arguing that compensation in such cases must be reasonable and adequately reflective of the loss suffered by the family.
Court’s Observations
The Supreme Court’s judgment featured detailed observations on the primacy of documents, the principles of compensation, and the role of appellate courts:
1. Primacy of the School Leaving Certificate:
– The bench noted that under Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015, the School Leaving Certificate holds statutory recognition and should be given precedence in cases of age determination. The Court observed, “Aadhaar is not per se proof of date of birth,” highlighting that while Aadhaar is valuable for identity verification, it is not designed to serve as conclusive proof of age.
– The judgment referred to prior High Court rulings that have similarly recognized school certificates as authoritative for determining age, particularly in juvenile and matrimonial cases. The Court cited several instances where Aadhaar was not accepted as conclusive proof of age, emphasizing that it is primarily an identity document.
2. Role of Appellate Courts in Compensation Cases:
– The Supreme Court criticized the High Court’s approach, emphasizing that an appellate court should not substitute its interpretation merely because a different conclusion is possible. The bench reiterated that intervention by an appellate court is warranted only when the lower court’s decision is marred by “perversity or illegality.” The Court stated, “Appellate courts are not meant to interfere merely to introduce a different view; the MACT’s decision must be respected unless it is patently erroneous.”
3. Principle of Just Compensation:
– The Supreme Court underscored that compensation in motor accident cases must be just and reasonable. The Court stressed that the amount must fairly reflect the loss suffered by the claimants and that lower courts must ensure that the compensation process is guided by the principles of fairness and adequacy. It criticized the High Court’s arbitrary reduction of compensation and reinstated the original calculations made by the MACT.
4. Rate of Interest:
– The bench found no justification for the reduction of the interest rate from 7.5% to 6% by the High Court. It observed that the interest rate must adequately compensate for the delayed justice faced by the claimants. As a result, the Court increased the interest rate to 8%, recognizing the impact of inflation and the urgency of financial relief to the family.
The Supreme Court set aside the High Court’s order and reinstated the original award by the MACT, adjusting the compensation to Rs. 15 lakh with 8% interest from the date of filing the claim petition. The Court accepted the School Leaving Certificate as the authoritative document for determining the age of the deceased, leading to the application of a multiplier of 14 in calculating the compensation.
Case Details
– Case Title: Saroj & Ors. vs. IFFCO-Tokio General Insurance Co. & Ors.
– Case No.: SLP(C) Nos. 23939-40 of 2023
– Bench: Justice Sanjay Karol and Justice Ujjal Bhuyan
