Bench emphasises primacy of contemporaneous service records and procedural fairness, quashes reinstatement based on identity documents alone.
Indore, January 14, 2026: The Madhya Pradesh High Court has held that Aadhaar and Voter Identity Cards cannot be treated as conclusive proof of a person’s date of birth in service-related disputes, particularly where such documents are relied upon to disturb settled employment records.
Court & Bench
The judgment was delivered on January 13, 2026, by a Single Judge Bench of Justice Jai Kumar Pillai of the Madhya Pradesh High Court, Indore Bench.
Case Title and Background
The petition titled Pramila v. State of Madhya Pradesh & Ors. arose out of a service dispute involving the appointment and subsequent termination of an Anganwadi Sahayika (helper). The matter concerned conflicting records of age and date of birth of a retired Anganwadi worker, whose successor was appointed based on retirement.
The retired worker, claimed that her date of birth had been incorrectly recorded in formal service records. She sought correction of her birth date to an entry shown in her Aadhaar card and Voter ID, which reflected a later birth year, and after many years, successfully obtained an appellate order reinstating her in service. As a consequence, the petitioner, who had been lawfully appointed to the post after Hirlibai’s retirement, was summarily terminated.
The petitioner challenged these orders before the High Court on multiple grounds, including alleged violation of natural justice, delay in filing the appeal, and improper reliance on identity documents for determining date of birth.
Legal Issue
The principal legal issue before the High Court was whether identity documents such as Aadhaar Cards and Voter Identity Cards, which are based on self-declaration and prepared years after initial service entry, can override contemporaneous official service records to determine a person’s date of birth in service matters.
Final Ruling
The High Court allowed the writ petition, quashing both the appellate order that reinstated Hirlibai and the consequent termination of Pramila’s appointment. The Court directed the respondents to reinstate the petitioner to the Anganwadi Sahayika post with continuity of service and full benefits, and to recover salaries and benefits paid to Hirlibai after her retirement.
Reasoning of the Court
In its reasoning, the High Court observed:
- Service records prepared at the time of entry into employment and relied upon throughout the entire career enjoy a presumption of correctness in determining tenure, seniority, and superannuation.
- Aadhaar and Voter ID documents, created much later and based on self-declaration, are primarily meant for identification purposes and lack statutory force as primary evidence of age in service disputes.
- The appellate authority had ignored the doctrine of delay and laches, since the retired worker had accepted the earlier date of birth throughout her service and did not challenge it at the appropriate time, causing prejudice to the successor employee.
- There were procedural infirmities and violations of natural justice in the appellate process, including failure to give the petitioner notice or an opportunity to be heard before terminating her services.
- The Court also noted inconsistencies in the claimed date of birth, such as the dates of birth of the retired employee’s children preceding her own claimed date, further undermining reliance on the identity documents.
Practical Implications
- Evidentiary Hierarchy in Service Disputes: The ruling reinforces that official service records prepared contemporaneously carry greater evidentiary weight in age determination than later-issued identity documents like Aadhaar and Voter ID.
- Finality of Service Records: Challenges to age or service-related entries must be raised promptly and cannot be used opportunistically years after retirement to unsettle settled administrative actions.
- Procedural Fairness: The judgment underscores adherence to natural justice principles in appellate proceedings affecting employment status, especially where third parties are impacted by corrective orders.
- Administrative Stability: For public employment frameworks, particularly in schemes with single incumbents, reopening retirement records without compelling primary evidence can cause administrative instability, affecting successors and service continuity.
The judgment adds clarity on the limited evidentiary value of Aadhaar and Voter ID cards as proof of date of birth in service law, reinforcing the primacy of contemporaneous official records and procedural safeguards in employment disputes.
