MP High Court Delivers Landmark Ruling on Age Proof Documents
The Madhya Pradesh High Court has made a significant ruling regarding age verification in employment cases. Justice Jai Kumar Pillai set aside orders that reinstated a retired Anganwadi worker and terminated her successor. The court clearly stated that Aadhaar and voter ID cards cannot serve as conclusive proof of date of birth for service matters.
Court's Reasoning on Identity Documents
Justice Pillai explained the fundamental limitation of these common identification documents. He emphasized that both Aadhaar cards and voter ID cards are prepared based on self-declaration by individuals. These documents primarily serve identification purposes in daily life. However, they do not qualify as statutory proof when determining age for employment-related decisions.
The court specifically noted: "These documents are prepared on the basis of self-declaration and are meant for identification purposes alone. They are neither primary evidence nor statutory proof for determination of age in service matters."
Service Records Take Precedence
The ruling establishes an important legal principle regarding employment records. When an employee accepts the date of birth recorded in official service documents and allows this information to become finalized, they cannot challenge it after retirement. The court found that the Appellate Authority had completely overlooked this established legal doctrine.
Justice Pillai applied the doctrine of delay and laches, which becomes particularly relevant in service jurisprudence after retirement. Once the employer-employee relationship ends through retirement, reopening settled matters creates administrative uncertainty. Such actions can also cause injustice to third parties who may be affected by the decisions.
Background of the Case
The legal dispute began when Pramila received appointment as Anganwadi Sahayika at the Jamli centre in Dhar district. Her selection followed a regular process after the previous worker, Hirlibai, reached superannuation and retired from the position.
Nearly two years after her retirement, Hirlibai approached the Additional Collector in Dhar with a claim. She argued that her date of birth had been incorrectly recorded in official documents. Relying on entries from her Aadhaar card and voter ID card, the appellate authority allowed her appeal in September 2020. This decision resulted in orders for her reinstatement.
Authorities acted on these orders by reinstating Hirlibai and removing Pramila from her position. This action prompted the legal challenge that eventually reached the High Court.
Court's Final Directions
The High Court issued clear directions to resolve the situation. The court ordered the reinstatement of petitioner Pramila to her position as Anganwadi Sahayika at Anganwadi Centre Jamli (Ambapura). The ruling includes continuity of service and all consequential benefits for Pramila.
These benefits encompass notional seniority and monetary compensation for the period she was removed from service. The decision reinforces the importance of finality in employment records and prevents disruption of settled administrative matters.
This ruling establishes important clarity for employment disputes across Madhya Pradesh and potentially beyond. It distinguishes between identification documents and statutory proof for age determination in service matters. The judgment emphasizes that once employment records achieve finality, they should not be reopened based on self-declared documents like Aadhaar or voter ID cards.
