The Madhya Pradesh High Court, while allowing an appeal for enhancement of compensation in a motor vehicle accident, observed that an Aadhaar card cannot, by itself, be treated as conclusive proof of the age of the deceased and that the age recorded in the postmortem report is more reliable. [2026 LiveLaw (MP) 453]

The bench of Justice Amit Seth observed:

"An Aadhaar Card is primarily an identity document and cannot, by itself, be treated as conclusive proof of the age of its holder. On the other hand, the age recorded in the postmortem report is based upon medical assessment conducted in the course of postmortem examination. Therefore, in the facts and circumstances of the present case, this Court finds the medical opinion recorded in the postmortem report to be a more reliable basis for determining the age of the deceased. Accordingly, the age of the deceased is taken as 13 years at the time of the accident". 

A miscellaneous appeal was filed under Section 173 of the Motor Vehicles Act by the appellants seeking enhancement of the compensation awarded by the Motor Accident Claims Tribunal, wherein compensation of ₹5,45,000 along with interest of 6% per annum was awarded for the death of a minor in an accident that occurred on December 24, 2019. 

The counsel appearing for the appellants submitted that, at the time of the accident, the deceased was a minor and his notional income was considered at ₹25,000 per month. It was claimed that the notional income ought to have been ascertained on the kko basis of the minimum wages payable to a person with the same qualifications, i.e., ₹7,950 per month. 

The counsel for the Insurance Company claimed that the appellant has enhanced the valuation of the appeal from ₹3 Lakhs to 8 lakhs and has paid the court fees for said enhancement on October 12, 2026. Therefore, the appellants are held entitled to the enhancement; the interest amount may be directed to be computed from the date of payment of the enhanced court fees. 

The court noted that the notional income of the deceased ought to have been assessed on the basis of minimum wages payable to an unskilled workman prevailing on the date of the accident. The court referred to the Madhya Pradesh State Legal Services Authority (MPSLSA Guidelines) and noted that the monthly income is taken at ₹7,950, which makes the annual income ₹95,400. 

Further, the bench noted that the age of the deceased was taken from the Aadhaar Card, which was determined at 14 years, 7 months, and 9 days. However, the post-mortem report recorded the age of the deceased as 13 years. 

Referring to the case of Divya v National Insurance Company Ltd., the court reiterated that the appropriate multiplier in the present case was 15 and not 18, as applied by the claims tribunal. 

Thus, the bench held that the appellants are entitled to total compensation of ₹8,25,500 as against ₹5,45,000 awarded by the tribunal. Accordingly, the appeal was partly allowed. 

Also Read: Aadhaar Card Age Not Conclusive: AP High Court Relies On Age Mentioned In Post-Mortem Report To Enhance Accident Compensation

For Appellants: Advocate Dharmendra Rishiwar 

For Insurance Company: Advocate Bal Krishna Agrawal