Supreme Court Enhances Motor Accident Compensation: Aadhaar vs. School Certificate for Age Determination

The case of Saroj & Ors. vs. IFFCO-TOKIO General Insurance Co. & Ors. revolves around a tragic road accident and the legal battle for fair compensation for the victim’s family. The key legal questions addressed by the Supreme Court in this judgment include the correct application of notional income, the choice of the applicable multiplier in computing compensation, and the evidentiary value of Aadhaar cards versus school certificates in determining the age of the deceased. The Court ultimately ruled in favor of the claimants, increasing the compensation awarded to them.

Case Background

On August 4, 2015, the deceased, Silak Ram, was traveling on a motorcycle along with Rohit when they were found lying injured on the side of the road. Silak Ram succumbed to his injuries, while Rohit was hospitalized. The police registered an FIR under Sections 279, 337, and 304A of the Indian Penal Code (IPC) based on the statement of Rohit, who identified the details of the offending vehicles.

Read also: https://judgmentlibrary.com/motor-accident-compensation-supreme-court-rules-in-favor-of-victims-family/

The family members of the deceased filed a claim petition before the Motor Accident Claims Tribunal (MACT) in Rohtak, Haryana, seeking compensation for their loss. The MACT awarded Rs. 19,35,400/- with an interest rate of 7.5%, directing that the minor children’s share be placed in fixed deposits until they reached adulthood.

However, the High Court of Punjab and Haryana reduced the compensation to Rs. 9,22,336/- on the grounds that:

• The deceased’s monthly income should be computed using the state-wide minimum wage rates rather than the special Deputy Commissioner (DC) rates applicable to Rohtak.
• The deceased’s age at the time of death should be taken from the Aadhaar card instead of the School Leaving Certificate, thereby affecting the multiplier used in calculating compensation.

Aggrieved by the reduction, the claimants approached the Supreme Court.

Petitioners’ Arguments

• The family argued that the High Court wrongly considered the Aadhaar card as proof of age, instead of the School Leaving Certificate.
• They contended that the deceased was earning more than what was assessed by the High Court and that the special DC rates should have been applied.
• The multiplier should have been 14, based on the age determined by the School Leaving Certificate (45 years), rather than 13, which was applied using the Aadhaar card data (47 years).

Respondents’ Arguments

• The insurance company argued that the High Court correctly used uniform minimum wage rates applicable throughout the state rather than district-specific rates.
• They maintained that the reduction in interest rate from 7.5% to 6% was justified.
• They insisted that the Aadhaar card was a valid proof of age and could override the School Leaving Certificate.

Supreme Court’s Observations

• The Court emphasized that appellate courts should not substitute their views unless the lower court’s decision is perverse or illegal.
• The High Court incorrectly applied the minimum wage rates instead of the special DC rates, despite no evidence that the deceased was ineligible for the latter.
• The deceased was an agriculturist and owned a tractor and JCB machine, which corroborated his higher income.
• The Court ruled that the School Leaving Certificate holds more weight as proof of age compared to an Aadhaar card, which is primarily an identity document.
• It highlighted that compensation should be just and reasonable, and reducing interest rates without valid reasoning was improper.

Supreme Court’s Ruling

• The deceased’s age should be determined using the School Leaving Certificate, making him 45 years old at the time of death.
• The applicable multiplier should be 14 instead of 13.
• The monthly income should be Rs. 9,000 as assessed by MACT, rather than the lower estimate by the High Court.
• The total compensation was recalculated to Rs. 14,41,500, which was rounded off to Rs. 15,00,000.
• The interest rate was increased from 6% to 8%, effective from the date of the claim petition.

Final Compensation Breakdown

Conclusion

The Supreme Court’s ruling ensures fair compensation for the deceased’s family, setting a precedent for similar cases. It affirms that School Leaving Certificates hold primacy over Aadhaar cards for determining age in compensation matters and upholds the principle of just and reasonable compensation for accident victims.

Read also: https://judgmentlibrary.com/supreme-court-enhances-compensation-in-road-accident-claim-key-legal-takeaways/

Petitioner Name: Saroj & Ors..
Respondent Name: IFFCO-TOKIO General Insurance Co. & Ors..
Judgment By: Justice Sanjay Karol, Justice Ujjal Bhuyan.
Place Of Incident: Rohtak, Haryana.
Judgment Date: 24-10-2024.

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