Aadhaar, Voter ID Cards Not Conclusive Proof Of Date Of Birth: MP High Court

The Madhya Pradesh High Court on Tuesday (January 13) held that Aadhaar and Voter ID cards are not conclusive proof of a person's date of birth.

The bench of Justice Jai Kumar Pillai observed;

"it is evident that the Aadhaar Card and Voter Identity Card relied upon by Respondent No.5 cannot be treated as determinative proof of her date of birth. These documents are prepared on the basis of self-declaration and are meant for identification purposes alone."

A writ petition was filed challenging the order passed by the Additional Collector of District Dhar. The Additional Collector had allowed the plea of Hiralal Bai (respondent no 5) challenging her superannuation. As a consequence, Hiralal Bai was reinstated as Anganwadi Sahayak, and the petitioner was removed from service, as there was only one sanctioned post of Anganwadi Sahayak.

Per the petitioner, she was appointed as Anganwadi Sahayak after a selection process was conducted following the policy guidelines issued by the Women and Child Development Department. She was issued an appointment order in June 2018.

It was further stated that Hiralal Bao was previously working on the same post, and per the office service record, she was superannuated at the age of 62 years. This order of superannuation was never questioned or challenged by Hiralal Bai.

After the post became vacant, the competent authority issued an advertisement and completed the selection process.

Hirlalal Bai filed an appeal nearly two years after her retirement, claiming that her date of birth was wrongly recorded and she was not born on March 5, 1955, but rather on January 1, 1964, based on her Adhaar card and Voter ID card.

The counsel for Hirlalal Bai submitted that once the appellate authority set aside the order of her superannuation, the department was bound to comply with the same, as there existed only one sanctioned post for the Anganwadi Sahayak.

The court noted that Hiralal Bai stood retired on March 5, 2017, based on the date of birth in her official service record. It reiterated that an employee who accepts the date of birth recorded in service records and allows it to attain finality cannot be permitted to challenge the same after retirement.

The court observed, "Appellate Authority completely ignored the doctrine of delay and laches, which is fatal in service jurisprudence. Once a person retires from service, the relationship of employer and employee comes to an end and reopening settled issues after retirement causes administrative uncertainty and injustice to third parties, as has happened in the present case".

The court reiterated that in service matters, the date of birth recorded in official service records enjoys a presumption of correctness and remains the basis for the determination of service tenure, seniority and superannuation. Therefore, the challenge to such an entry must be raised at the earliest and supported by impeachable evidence.

The court further noted that the petitioner was never afforded an opportunity of hearing before passing the impugned order resulting in the termination of her service.

The bench emphasised that any administrative or quasi-judicial orders that have civil consequences must follow the principles of natural justice, particularly the doctrine of Audi Alteram Partem.

Therefore, the bench held that the order of the appellate authority was void and that the order terminating the petitioner's service was unsustainable.

Thus, the bench quashed the impugned orders and directed the respondents to reinstate the petitioner to the post.

Case Title: Pramila v State of Madhya Pradesh [2026:MPHC-IND:103]

For Petitioner: Advocate Akshay Bhonde

For State: Government Advocate Amit Bhatia

For Hiralal Bai: Advocate S.P. Pandey

Click here to read/download the Order