Mere Admission Of Different Date Of Birth Not Better Proof Than School Leaving Certificate: Orissa High Court
🧾 Case Overview: Madan Raul v. State of Odisha & Others
Citation: WP(C) No. 2499 of 2022
Bench: Justices Arindam Sinha and Sanjay Kumar Mishra
Date: December 1, 2023
Issue: Dispute over the correct date of birth of an employee, with the school leaving certificate indicating a different date than the one recorded in the service book.
⚖️ Court's Rationale
Evidentiary Value of School Leaving Certificate
The Court emphasized that a school leaving certificate is a significant documentary proof of a person's date of birth. It noted that such certificates are issued based on school admission registers, which are maintained contemporaneously with the student's admission. Therefore, the date of birth recorded therein holds substantial evidentiary value.
Admissions Are Not Conclusive Proof
While admissions made by a person regarding their date of birth are relevant, they are not conclusive proof. The Court referred to Section 31 of the Indian Evidence Act, 1872, which states that admissions are not conclusive proof but may operate as estoppel under certain circumstances. Thus, an admission of a different date of birth cannot override the documentary evidence provided by the school leaving certificate.
Importance of Documentary Evidence
The Court highlighted the importance of documentary evidence in establishing facts. In this case, the school leaving certificate, being a public document, was given precedence over the individual's admission of a different date of birth. The Court's decision underscores the principle that documentary evidence, especially when contemporaneous and official, carries more weight than oral admissions.
📚 Legal Precedents
Section 31 of the Indian Evidence Act, 1872: This section deals with the relevancy of admissions. It states that an admission is a statement, oral or written, made by a party in a case or by the agent of such a party, acknowledging the existence of a matter of fact. However, such admissions are not conclusive proof and can be rebutted by other evidence.
Case Law Reference: In Madan Raul v. State of Odisha & Others, the Court applied these principles to assert that the school leaving certificate, being a public document, holds more evidentiary value than the individual's admission of a different date of birth.
✅ Conclusion
The Orissa High Court's decision reinforces the principle that documentary evidence, particularly public documents like school leaving certificates, holds significant weight in legal proceedings. While admissions can be relevant, they are not conclusive and can be challenged by stronger documentary evidence. This approach ensures that facts are established based on reliable and verifiable documents, maintaining the integrity of legal proceedings.
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