In recent years, Aadhaar has emerged as one of India's most widely accepted identification tools, used across domains to streamline access to services and verify individual identity. Aadhaar's primary purpose, as mentioned in the Aadhaar Act of 2016[1] was to confirm identity for government-funded benefits and subsidies, using its unique, biometric-based system.

Yet, Aadhaar's utility has expanded far beyond this initial scope, making it easier for the public to access essential services[2] like banking, mobile SIMs, paperless e-KYC etc. without needing multiple forms of identification. However, while Aadhaar's role in identity verification is broad, its use in verifying certain details, such as age, remained legally contentious.

Despite Aadhaar's prominence, recent judicial pronouncements underscored its limitations in providing conclusive age proof in legal settings. The Supreme Court recently addressed this issue in Saroj v. Iffco-Tokio General Insurance Co.[3], setting a precedent by limiting the admissibility of Aadhaar as age-proof. The Court overturned a High Court ruling that had accepted Aadhaar for age verification in a motor accident compensation case. In its decision, the bench of Justice Sanjay Karol and Justice Ujjal Bhuyan emphasized that an Aadhaar Card does not provide conclusive proof of age, underscoring its limitations in legal contexts.

Case Background
This Supreme Court case originated from a motor accident claim following the death of an individual on August 4, 2015. The Motor Accident Claims Tribunal (MACT) in Rohtak initially awarded the deceased's family ₹19,35,400 in compensation. However, the Panjab and Haryana High Court subsequently reduced this amount to ₹9,22,336, primarily due to a discrepancy regarding the deceased's age.

Relying on the Aadhaar card, which recorded his date of birth as January 1, 1969, the High Court calculated his age as 47 years at the time of death and applied a compensation multiplier of 13 accordingly, resulting in a lowered award. The appellants, representing the deceased's legal heirs, contended that the High Court's reliance on the Aadhaar card was erroneous. They argued that the School Leaving Certificate, showing a birth date of October 7, 1970, accurately placed the deceased's age at 45 at the time of the accident, warranting a higher multiplier of 14 for compensation purposes.

Therefore, the question arising before the Supreme Court was: in the event of a discrepancy between dates of birth recorded in two separate documents—specifically, as in this instance, between a School Leaving Certificate and an Aadhaar Card-which document should be deemed authoritative?

Aadhaar As Age Proof: The Supreme Court's Perspective

Legal Standard for Age Verification: Section 94 of the Juvenile Justice Act, 2015

In its decision, the Court highlighted Sub-section (2) of Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015, as a key guideline for determining a person's age. According to Sub-section (2), if the Committee or Board has reasonable doubts about whether the individual is a child, they must begin an age verification process by gathering specific types of evidence in the following order:

1. The preferred evidence is a date of birth certificate from the school or, matriculation or equivalent certificate from the relevant examination board.
2. If the first option is unavailable, the next preferred document is a birth certificate issued by a municipal authority, corporation, or panchayat.
3. If neither of the above documents is available, then an ossification test or another advanced medical test may be conducted on the Committee's or Board's orders.

Rule 12 of the Juvenile Justice (Care and Protection of Children) Rules, 2007, provided a similar criterion for determining age in case of a child or a juvenile in conflict with law.

View of the High Courts:
While deciding the case, the bench of Justice Sanjay Karol and Justice Ujjal Bhuyan also relied upon several High Court rulings, most of which are discussed below.

In Jabbar v. State[4], the Delhi High Court evaluated whether an Aadhaar card could be used as legitimate age proof for the victim under Rule 12 of the Juvenile Justice Rules, 2007. In this case, the Court accepted the Aadhaar card as equivalent or even superior to a municipal birth certificate for proving the child's age, given that it is a government-issued document. (Para 37).

However, the Madhya Pradesh High Court in Manoj Kumar Yadav v. State of M.P.[5] took a different view and ruled that the age mentioned in the Aadhaar Card could not serve as conclusive proof of juvenility. Justice Vivek Agarwal held that the Aadhaar Card, though a unique identification document issued by the Indian Government, is not suitable for determining the age. (Para 5 to 8)

Similarly, in Sofikul Islam v. State of Kerala [6], the Kerala High Court examined the question of age verification under the Juvenile Justice Act, 2015. The appellant argued he was only 16 based on his Aadhaar card and a birth certificate from Assam's health department. However, his School Transfer Certificate indicated he was 19. The Court held that as per Section 94 of the Juvenile Justice Act, 2015, Aadhaar is not recognized as proof of age. Instead, school records or a matriculation certificate must be given priority, followed by a birth certificate from local authorities if school records are unavailable. (Para 16).

In Parvati Kumari v. State of U.P.[7], the Allahabad High Court, after reviewing an affidavit submitted by the Unique Identification Authority of India (UIDAI), noted that while Aadhaar serves as secure proof of identity through biometric verification, the personal information it displays—such as name, date of birth, and address-relies on self-declarations by the applicant. UIDAI itself clarified that it does not independently verify these demographic details. Consequently, the Court held that under the Evidence Act, entries of address, date of birth etc., in Aadhaar Card cannot be considered conclusive proof of those facts. (Para 27).

In Shahrukh Khan v. State of M.P.[8], the Madhya Pradesh High Court ruled that if the genuineness of the School Leaving Certificate is not under challenge, the said document must be given due primacy. The Court also held that the Aadhaar Card could not be used as proof of age, as it serves solely for identification purposes. (Para 16 and 17).

In Gopalbhai Naranbhai Vaghela v. Union of India & Anr.[9], the petitioner faced pension delays because of a discrepancy in his date of birth as mentioned in his School Leaving Certificate and Aadhaar Card. The Gujarat High Court ruled that the School Leaving Certificate should be considered as the primary proof of age to release the petitioner's pension. The court disregarded the date of birth mentioned in the Aadhaar card, deeming it irrelevant for this consideration. (Para 6)

In Shabana v. NCT of Delhi[10], the UIDAI clarified in the Delhi High Court that Aadhaar was not intended to serve as proof of date of birth. (Para 8).

Decision Of The Supreme Court
In Saroj, the Supreme Court reinforced the prevailing view held by numerous High Courts regarding the limited scope of Aadhaar as a document for determining age. In deciding the case, the Court referenced K.S. Puttaswamy v. Union of India[11], where Justice A.K. Sikri emphasized that the Aadhaar Act was designed to create a unique identification system to assign each individual a distinct, non-duplicable identity, focused on identity verification. The Court also cited the UIDAI's official clarification in Circular No. 08 of 2023 (page 9 of the Judgement), which explicitly says that Aadhar should not be used as proof of date of birth.

Highlighting the statutory hierarchy mentioned in Section 94 of the Juvenile Justice Act, 2015, the Court also accepted the conclusion drawn by different High Courts that documents like matriculation certificates, school leaving certificates and birth certificates carry greater probative value for age determination. Consequently, by referencing Puttaswamy, the various decisions from High Courts and the UIDAI's clarification, the Supreme Court affirmed that while Aadhaar is effective for identity verification, it does not carry the evidentiary value necessary for proving age. (Para 10).

Analysis
Across High Courts in India, a clear consensus has emerged: Aadhaar is not sufficient for age verification in cases where age is an important factor, whether in criminal, civil, or administrative matters. High Courts nationwide, apart from the Delhi High Court in Jabbar, have consistently ruled that Aadhaar's purpose is limited to identity verification, not as conclusive age proof. In Saroj, the Supreme Court not only accepted this stance but underscored the statutory framework for determining age outlined in Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015, which prioritizes official documents like matriculation certificates and birth certificates for age verification.

This judicial consensus provides clarity to Section 29 of the Bharatiya Sakshya Adhiniyam, 2023 (formerly Indian Evidence Act, 1872). Section 29 explains the relevancy of any entry in a public or official book, register or record made by a public servant in the discharge of their official duty. The Court's decision highlights that documents such as the matriculation certificate, school leaving certificate and birth certificates carry higher probative value for age verification due to their rigorous verification processes.

This aligns with UIDAI's own explanation in Parvati Kumari regarding the lack of authentication of the details related to date of birth, address etc. This Judgement of the Supreme Court reinforces the consensus: Aadhaar, while crucial for identity verification, falls short of the evidentiary standard required for age verification. This interpretation cautions against stretching Aadhaar's purpose beyond identity, thereby safeguarding accuracy in legal matters involving age verification.

CONCLUSION: CLARIFYING AADHAAR'S BOUNDARIES
The Supreme Court's ruling raises an important question for lawmakers: should Aadhaar's role be explicitly restricted to identity verification through formal legislative measures? While Aadhaar remains a valuable tool for authenticating identity, a clearer legal framework defining its limitations could prevent misuse and ensure that Aadhaar fulfils its intended purpose without exceeding its scope. Enhanced guidelines from the UIDAI could provide further clarity for institutions and government bodies and reinforce Aadhaar's role as an identity verification tool only.

These measures shall set boundaries to prevent its inappropriate use as a substitute for age-proof documentation. In addition, policymakers may explore public awareness programs to inform citizens of Aadhaar's limitations, particularly in relation to legal proceedings involving age verification.

As Aadhaar becomes more embedded in India's socio-legal framework, establishing clear boundaries and standardized policies for its use will be critical in avoiding legal ambiguities, ensuring reliable age verification, and maintaining compliance with legal standards across administrative and judicial platforms.

References:

1. The Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016. Act No. 18 of 2016.
2. UIDIA, Aadhaar Myth Busters, https://uidai.gov.in/en/my-aadhaar/about-your-aadhaar/aadhaar-myth-busters.html
3. SLP(C) Nos.23939-23940 of 2023
4. 2018 SCC OnLine Del 9327
5. 2023 SCC OnLine MP 1919
6. Bail Application No. 7321/2022
7. 2019 SCC OnLine All 7085
8. 2023 SCC OnLine MP 2740
9. Special Civil Application 16484/2022, Gujarat High Court
10. 2024 SCC OnLine Del 5058
11. 2019 (1) SCC 1