Aadhaar Date of Birth: Can You Change DOB in Service Record Using Aadhaar and Voter ID? High Court Answers
Aadhaar Date of Birth: In a significant ruling that underscores the sanctity of service records, the Madhya Pradesh High Court has clarified that Aadhaar cards and Voter Identity cards cannot be treated as conclusive proof of date of birth in service-related matters. The verdict came in the case of Pramila v. State of Madhya Pradesh & Ors., delivered by Justice Jai Kumar Pillai.
The Court emphasized that service records, which are prepared at the time of an employee’s entry into service and relied upon throughout their career, hold higher evidentiary value than identity documents created much later.
Service Records vs. Identity Documents
Justice Pillai noted that documents like Aadhaar and Voter ID cards are primarily meant for identification purposes. They are often generated based on self-declaration and, in many cases, are created years after an employee has joined the service. Therefore, these documents cannot override the official date of birth recorded in the service book at the time of appointment.
The Court stated, “These documents… are neither primary evidence nor statutory proof for determination of age in service matters.”
The Case Background
The dispute arose from the appointment of an Anganwadi Sahayika (Helper) and the subsequent reinstatement of her retired predecessor.
- The Petitioner: Pramila was appointed as an Anganwadi Sahayika in June 2018 through a proper selection process.
- The Respondent: Her appointment filled the vacancy left by Hirlibai, who had retired in March 2017 based on her official service records.
- The Conflict: Two years post-retirement, Hirlibai challenged her retirement date. She produced her Aadhaar and Voter ID cards, claiming her birth year was 1964—nearly nine years later than what was in her service records.
- Appellate Order: Surprisingly, the appellate authority accepted her claim in September 2020, reinstating Hirlibai and terminating Pramila’s service.
Fact-Checking by the Court
The High Court found glaring inconsistencies in Hirlibai’s claims. Beyond the documentary evidence, the Court looked at biological plausibility.
- The Court observed that the recorded birth years of Hirlibai’s son and daughter-in-law made it practically impossible for her to have been born in 1964.
- The dates in the Aadhaar card were deemed to be “approximate entries” used when proper proof is unavailable.
The following table summarizes the key contradictions noted by the Court:
| Comparison Point | Service Record | Aadhaar/Voter ID Claim |
|---|---|---|
| Nature of Evidence | Created at entry, relied on for career | Self-declared, created later |
| Date of Birth | Consistent with family facts | 1964 (Contradicted by son’s age) |
| Legal Validity | Primary Proof | Identity Proof Only |
Violation of Natural Justice
The High Court also highlighted serious procedural lapses in how Pramila was removed from her job.
- No Notice: Pramila was not made a party to the appeal filed by Hirlibai.
- Collateral Damage: She was terminated without any inquiry or valid reason, merely as a consequence of Hirlibai’s reinstatement.
- Unfair Process: The Court termed this a violation of the principles of natural justice and departmental guidelines.
The Verdict
The High Court quashed the 2020 appellate order and the termination of Pramila.
- Reinstatement: Pramila is to be reinstated with full service benefits.
- Recovery: Any salary or benefits paid to Hirlibai after her initial retirement must be recovered by the State, along with interest.
This ruling serves as a stern reminder that while Aadhaar is a critical document for identity, it does not automatically supersede established service records regarding an employee’s age.
