The recent judgment by the Allahabad High Court solidifies the legal validity of a matriculation certificate issued by a school as sufficient proof for determining an individual’s date of birth, emphasizing that a DNA test is unnecessary if such a certificate has not been disproven.
The ruling, derived from the Supreme Court’s directive in Aparna Ajinkya Firodia v. Ajinkya Arun Firodia, highlights that ordering a DNA test should be reserved for exceptional circumstances when no other legal means exist to establish the parentage of the person in question.
The case in question revolved around a dispute over land ownership. Yaqoob, the landholder, had three sons: Shakeel, Jameel, and Furkan. After Shakeel’s untimely demise, his wife, Smt. Mobin (Petitioner 1), claimed that they had a daughter (Petitioner 2) born from their union. However, contesting respondents alleged that Petitioner 2 was born from Shakeel’swife’s second marriage following Shakeel’s death. Moreover, it was argued that since Petitioner-wife didn’t attend to Shakeelduring his life, he executed a Will in favor of his two brothers—the contesting respondents.
Petitioners’ contentions about Petitioner 2’s parentage, backed by her High School certificate displaying her birthdate (04.05.1999), were rebutted based on Shakeel’s death date (27.07.1997). The authorities and courts dismissed their claims, culminating in the matter reaching the Allahabad High Court after unsuccessful challenges before multiple authorities.
The High Court’s verdict heavily relied on the Juvenile Justice Act’s stipulation, acknowledging educational certificates like the High School certificate as the most credible evidence to determine an individual’s date of birth. Highlighting the significant 615-day gap between Shakeel’s death and Petitioner 2’s birth, the Court arrived at the conclusion that Shakeel could not possibly be her father.
In the case of Smt. Mobin And Another v. Dy. Director Of Consolidation And 6 Others, the Allahabad High Court leaned on established legal principles, particularly those laid down by the Supreme Court in the case of Aparna Ajinkya Firodia v. Ajinkya Arun Firodia. This reference was pivotal in highlighting the significance and credibility attributed to a matriculation certificate in the context of validating an individual’s date of birth. The court stressed that a matriculation certificate stands as a robust and acceptable document for ascertaining one’s date of birth, thereby rendering unnecessary the need for resorting to a DNA test, specifically when determining paternity.The reliance on the Supreme Court’s guidelines from Aparna Ajinkya Firodiav. Ajinkya Arun Firodia served as a cornerstone for the High Court’s decision. This reference underscored the pivotal role played by a matriculation certificate as a legally recognized and credible document in establishing an individual’s date of birth. By emphasizing the matriculation certificate’s credibility, the High Court explicitly negated the necessity for conducting a DNA test to verify paternity or parentage.
Additionally, the Court pointed out that Petitioner 2, now an adult, had not made any claim or assertion regarding her rights over the disputed land, further reinforcing the conclusions drawn from the evidence presented.
Consequently, the Court upheld the decisions made by the lower authorities, stating that no modifications could be made to the Will favoring the contesting respondents.
The judgment reinforces the significance and credibility of educational certificates like the matriculation certificate in legal matters concerning determining an individual’s date of birth. By relying on the Supreme Court’s established principles, the High Court reiterates that a DNA test should not be a routine recourse in cases where substantial legal documentation, such as a matriculation certificate, exists to establish facts regarding parentage or date of birth.
This ruling stands as a crucial precedent, emphasizing the reliability and evidentiary weight accorded to educational certificates in legal proceedings. Moreover, it reaffirms the principle that extraordinary circumstances warrant DNA tests and that the existence of documentary evidence should take precedence in determining crucial aspects such as parentage or date of birth.