When Identity Documents Yield To Service Record: Aadhar And Voter Id Cards Not Conclusive Proof Of Date Of Birth

Posted On - 21 January, 2026 • By - Ishika Soni

Aadhar and Voter ID not conclusive proof of date of birth

Introduction

The question of determining a public servant’s date of birth has long occupied a central place in Indian service jurisprudence. While courts have consistently emphasized the sanctity of official service records, recent years have witnessed a growing tendency to rely on identity documents such as Aadhar Cards and Voter ID Cards to reopen settled service matters.

In Pramila v. State of Madhya Pradesh (2026:MPHC-IND:1034), the Madhya Pradesh High Court decisively addressed this issue. The Court held that Aadhar Cards and Voter ID Cards are not conclusive proof of date of birth, especially when invoked to challenge long-settled service records after superannuation. The judgment is notably not only for reaffirming settled principles of service law but also for protecting third-party rights and reinforcing procedural fairness.

Importance of Date of Birth in Service Law

In public employment, the recorded date of birth is not a mere personal details, it forms the foundation of service tenure, governing:

Eligibility for appointment;
Seniority;
Promotion;
Superannuation;
Pensionary and retiral benefits.

Indian Courts have consistently held that the date of birth recorded at the time of entry into service carries a presumption of correctness. Permitting belated challenges disrupts administrative certainty, creates chaos in service administration, and prejudices other employees.

Factual Matrix of the Case

The Petitioner, Pramila, was appointed as an Anganwadi Sahayika at Anganwadi Centre, Jamli (Ambapura), following a duly notified selection process conducted in accordance with the policy guidelines of the Women and Child Development Department, Government of Madhya Pradesh. After due verification of eligibility and merit, she was issued an appointment order dated 19^th June, 2018 and continued to discharge her duties satisfactorily.

Prior to the petitioner’s appointment, the post was held by Respondent No. 5, HirliBai, whose official service records recorded her date of birth as on 05^thMarch 1955. On attaining the age of 62 years, she was superannuated on 05^th March, 2017. Notably, the order of superannuation was never questioned or challenged at the relevant time. After her retirement, the post fell vacant, leading to a fresh recruitment process and the petitioner’s appointment.

Procedural History

Nearly two years after retirement, Respondent No. 5, HirliBai filed an appeal before the Additional Collector, District Dhar, claiming that her date of birth had been incorrectly recorded. She asserted that her actual date of birth was 01 January 1964, relying exclusively on her Aadhar Card and Voter ID Card.

The Additional Collector allowed the appeal on 01 September, 2020, set aside the order of superannuation, and directed her reinstatement. Consequently, by order dated 21^st November 2020, the petitioner was removed from service on the ground that there existed only one sanctioned post. Crucially, the petitioner was neither impleaded nor heard during the appellate proceedings.

Aggrieved, the petitioner approached High Court under Article 226 of the Constitution of India.

Issues Raised

Whether a retired employee can challenge her recorded date of birth after superannuation?
Whether Aadhar Cards and Voter ID Cards constitute the proof of date of birth in service matters?
Whether the appellate authority erred in ignoring delay, laches, and settled service records?

Submissions of the Parties

Petitioner:

The appeal was barred by gross delay and laches.
Aadhar and Voter ID Card lacks the evidentiary value in the service law matters as per the established jurisprudence.
Her termination without the notice and hearing violated Audi Alteram Partem, principle established by the Apex Court of the country.
She acquired a legitimate civil rights through a lawful appointment.

Respondent:

The appellate order setting aside the superannuation was binding and true in law.
With only one sanctioned post, reinstatement of Respondent No. 5 necessitated removal of the petitioner.

Judicial Analysis & Findings

The Madhya Pradesh High Court undertook a detailed examination of the legality and propriety of the orders passed by the Additional Collector and the consequential termination of the petitioner’s service.

Challenge to Superannuation after Retirement

At the outset, the Court notes that it was undisputed that Respondent No. 5 stood retired on 05^th March 2017, based on the date of birth recorded in the official service records. The said entry remained unchallenged throughout her entire service tenure and even at the time of retirement.

The Court reiterated the settled legal position that once an employee accepts the date of birth recorded in the service records and allows it to attain finality, she cannot be permitted to challenge the safe after superannuation. Such challenges, if entertained, would undermine administrative certainty and disrupt settled service positions.

The Bench observed that the respondent in the present case allowed the order of superannuation to remain unquestioned for nearly two years, and only thereafter sought to reopen the issue by filing an appeal before the Additional Collector. This delay, according to the Court, was not only unexplained but also legally fatal.

Doctrine of Delay and Laches in Service Matters

The Court came down heavily on the Appellate Authority for completely ignoring the doctrine of delay and laches, which occupies a central place in service law. Emphasizing the consequences of reopening settled service matters, the Court observed:

“The 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 the third parties, as has happened in the present case.”

The Bench highlighted that service jurisprudence does not merely protects individuals claims but also safeguards the rights of third parties who may have been lawfully appointed against a vacant post.

Evidentiary Value of Aadhar Card & Voter ID Card

A central issue before the Court was whether Aadhar Cards and Voter ID Cards could be treated as conclusive proof of date of birth for the purpose of altering the service records.

The Bench of Justice Jai Kumar Pillai categorically rejected such reliance and observed:

“It is evident that the Aadhar Cards and Voter ID Cards 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 purpose alone.”

The Court noted that identity documents like Aadhar Cards and Voter ID Cards are not prepared after any adjudicatory or verification process concerning age. Instead, they are largely based on self-declaration particulars furnished by the individual and therefore lacks the evidentiary sanctity in service matters.

The Bench further observed that in service jurisprudence, the date of birth recorded in official service records enjoys a presumption of correctness, as such entries are made at the time of entry into the service and remain the basis for determining service tenure, seniority, and superannuation. Any challenge to such an entry must be raised at the earliest opportunity and must be supported by impeccable and unimpeachable evidences, which was conspicuously absent in the present case.

Violation of Principle of Natural Justice

Another crucial infirmity identified by the Court was the complete denial of opportunity of hearing to the petitioner. The Court noted that the petitioner was neither impleaded as a party in the appeal nor served with any notice before passing the order dated 01 September 2020, despite the fact that she was lawfully holding the post pursuant to a valid appointment.

The court emphasized that any administrative or quasi-judicial order that entails civil consequences must adhere to the principles of natural justice, particularly the doctrine of audi alteram partem.

Court’s Reliance on Precedents

While adjudicating the issue, the High Court placed reliance on settled law laid down by the Hon’ble Supreme Court, holding that the question is no longer res integra. The Bench drew strength from the authoritative pronouncement in Saroj & Ors. v. IFFCO-Tokio General Insurance Co. & Ors., Civil Appeal arising out of SLP (C) Nos. 23939–23940 of 2023, wherein the Apex Court unequivocally clarified the limited evidentiary scope of Aadhaar Cards. The Supreme Court, after taking note of UIDAI Circular No. 08 of 2023 and the Office Memorandum dated 20 December 2018 issued by the Ministry of Electronics and Information Technology, held that while an Aadhaar Card may serve as proof of identity, it does not constitute conclusive proof of date of birth.

The Apex Court further noted that Aadhaar particulars are largely based on information furnished by the individual and are not the product of any adjudicatory or statutory age-verification mechanism. This position was also earlier recognised by a Division Bench of the Bombay High Court in State of Maharashtra v. UIDAI, Criminal Writ Petition No. 3002 of 2022, thereby lending consistent judicial affirmation to the principle that Aadhaar cannot override statutory or service records for determination of age.

Further, the Madhya Pradesh High Court also relied upon the judgment of the Allahabad High Court in Ram Kripal alias Chirkut v. Deputy Director of Consolidation & Others, Civil Misc. Writ Petition No. 13286 of 1981, wherein the evidentiary value of entries in voter lists and voter identity cards was examined. The Allahabad High Court categorically held that voter lists are prepared on the basis of self-serving statements furnished by individuals and, in the absence of proof as to the material on which such entries were made, cannot be treated as reliable evidence for determining actual date of birth. Applying these settled principles, the Madhya Pradesh High Court concluded that neither Aadhaar Cards nor Voter Identity Cards qualify as primary or statutory proof of age in service matters, particularly when sought to unsettle long-finalised service records after superannuation.

Judgment and Final Directions

In view of the foregoing analysis made, the Madhya Pradesh High Court held that the order passed by the Additional Collector allowing the appeal of Respondent No. 5 was unsustainable in law. Consequently, the order reinstating Respondent No. 5 and terminating the petitioner’s services was also held to be legally invalid.

The Court, therefore:

Held Aadhar Cards and Voter ID Cards do not override official service records.
Quashed the order dated 01 September 2020 passed by the Additional Collector, District Dhar.
Set aside the consequential order dated 21^st November 2020 terminating the petitioner’s services.
Directed reinstatement of the petitioner to the post of Anganwadi Sahayika with continuity of service and all consequential benefits, including notional seniority and monetary benefits as admissible in law.

In a significant further direction, the Court ordered that the entire amount paid to the Respondent No. 5 towards the salary and other monetary benefits after her superannuation be recovered with 6% interest per annum and deposited with the state exchequer.

This ruling reinforces that identity documents cannot be used as a whole or tools to unsettle long- finalised service records, particularly after the superannuation. It also reaffirms the judiciary’s commitment to protecting third-party rights and ensuring strict adherence to natural justice in administrative decision-making.

Conclusion

The judgment in Pramila v. State of Madhya Pradesh is a clear reaffirmation of settled service law. It protects administrative certainty, prevents misuse of identity documents, and safeguards the rights of employees appointed through lawful processes. The Court’s insistence on procedural fairness strengthens confidence in public administration.

Author’s View

The ruling strikes a careful balance between administrative discipline and individual rights. By rejecting the misuse of Aadhar Cards and Voter ID Cards as age-proof in service matters, the Court prevents retrospective manipulation of service tenure. The Judgment serves as a timely reminder that identity documents cannot be elevated above the statutory service records, and that fairness to third parties is an indispensable component of administrative justice.

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