Madhya Pradesh High Court Prefers Postmortem Age Over Aadhaar in ₹8.25 Lakh Compensation Case

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The Madhya Pradesh High Court has ruled that an Aadhaar card cannot be treated as conclusive proof of age, holding that a postmortem report carries greater evidentiary value in determining the age of a deceased person. Justice Amit Seth, in an order dated November 3, 2026, enhanced the compensation awarded to the parents of a 13-year-old boy who died in a motor accident in December 2019. The court increased the award from ₹5.45 lakh, granted by the Bhind Motor Accident Claims Tribunal (MACT) on September 14, 2022, to ₹8.25 lakh.

The dispute arose over the boy's age: the MACT had determined it as 14 years, seven months and nine days based on his Aadhaar card, while the postmortem report assessed it as 13 years. The insurance company argued that the Aadhaar card was not conclusive proof of age and that the postmortem report, being scientific, should prevail. The high court agreed, stating that an Aadhaar card is primarily an identity document and cannot by itself be treated as conclusive proof of age, whereas the age recorded in the postmortem report is based on medical assessment conducted during the postmortem examination.

Applying the multiplier method, the court used a notional monthly income of ₹7,950, as per Madhya Pradesh State Legal Services Authority guidelines, resulting in an annual income of ₹95,400. Since the boy was below 15 years, the court applied a multiplier of 15 instead of 18. After deducting 50% for personal and living expenses, the loss of dependency was calculated at ₹7.15 lakh. The court added ₹40,000 for each parent as compensation for loss of parental consortium, ₹15,000 for funeral expenses, and ₹15,000 for loss of estate, bringing the total compensation to ₹8.25 lakh—an enhancement of ₹2.80 lakh.

What is the Supreme Court's multiplier method for accident compensation?

The multiplier method used to calculate loss of dependency in motor accident claims was standardised by the Supreme Court in the case of Sarla Verma v. Delhi Transport Corporation in 2009. The court prescribed specific multipliers based on the age of the deceased, ranging from 18 for those aged 15 to 25 years down to 5 for those aged above 65. For victims below the age of 15, the Supreme Court in the subsequent case of Kishan Gopal v. Lala in 2013 applied a multiplier of 15. The Motor Vehicles Act, 1988, under Section 166, provides the legal basis for filing such compensation claims before a Motor Accident Claims Tribunal.

How is age determined in motor accident compensation cases?

In motor accident claims, the age of the victim is crucial because it determines the multiplier used to calculate compensation for loss of dependency. The multiplier method multiplies the annual financial dependency by a fixed number representing estimated working years. The Supreme Court has established guidelines for notional income and multipliers based on age brackets. In this case, the MACT had used the Aadhaar card to determine age, but the high court held that medical evidence from a postmortem report is more reliable for age determination.

What did the court achieve and what remains unchanged?

The ruling establishes that Aadhaar alone is not conclusive proof of age, but it does not make postmortem evidence universally decisive in all cases—the court found it more reliable in the circumstances of this case. The compensation calculation followed standard principles: notional income of ₹7,950 per month, a multiplier of 15 for a victim below 15 years, and deductions for personal expenses. The court added heads of damages including parental consortium, funeral expenses, and loss of estate, consistent with established legal precedents.