01Facts
The Petitioners, 19-year-old twin brothers, were issued Aadhaar cards as minors in 2012.
¶ 3Upon attaining the age for mandatory biometric updates in 2022, they submitted the required data, but their requests were rejected due to "biometric mismatch".
¶ 3-4Over two years, the Petitioners repeatedly visited the UIDAI Regional Office, receiving conflicting instructions to first cancel existing numbers and later to seek updates, only for their numbers to be eventually suspended or cancelled.
¶ 4-6Consequently, as students, they faced prejudice in higher education admissions and insurance coverage.
¶ 5They approached the High Court seeking a mandamus for the biometric update or issuance of fresh Aadhaar cards.
¶ 302Issues
i.1. Whether a statutory authority can leave a resident in administrative limbo without a clear remedial pathway in cases of biometric mismatch.
¶ 12ii.2. Whether the Petitioners are entitled to fresh enrollment or biometric rectification under the Aadhaar Act and Regulations despite existing record anomalies.
¶ 1703Law Applied
Section 23 of the Aadhaar Act, 2016, regarding the authority’s power to manage enrollment and data, and Section 31 regarding the alteration of demographic/biometric information.
¶ 10Regulations 28 and 31 of the Aadhaar (Enrollment and Update) Regulations, 2016, which dictate the process for deactivation due to "bad data" and re-enrollment following omission.
¶ 11Justice K.S. Puttaswamy (Retd.) v. Union of India, emphasizing that Aadhaar must operate within constitutional limits of proportionality and exclusion safeguards.
¶ 13Comptroller and Auditor General of India v. K.S. Jagannathan, affirming the High Court’s power to issue mandamus when a public authority fails to exercise its discretion to fulfill statutory purposes.
¶ 15Provisions in the judgment · 2 · Linked ones open on LawLens
Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016. Section 23Section 31
04Reasoning
The Court reasoned that while UIDAI must maintain the integrity of the Central Identities Data Repository, the statutory scheme does not permit an "indefinite administrative limbo".
¶ 12The Court found that the Petitioners, having no allegations of fraud against them, were victims of inconsistent administrative communication.
¶ 16It held that under Regulation 31, if an Aadhaar number is omitted, the individual has a right to re-enroll.
¶ 11The Court reconciled the State's interest in data purity with the citizen's right to identity, concluding that the authority is duty-bound to provide a lawful, time-bound route to cure technical defects.
¶ 14, 17The Court invoked the maxim lex non cogit ad impossibilia, noting Petitioners cannot be expected to cure system-level mismatches except through prescribed UIDAI mechanisms.
¶ 1805Holding
The Court allowed the Writ Petition, directing the Petitioners to submit fresh applications for Aadhaar enrollment within fifteen days.
¶ 19The Respondents were directed to process these applications strictly under the 2016 Act and Regulations within four weeks, without rejecting them solely based on prior biometric mismatches.
¶ 19-20The Court issued eight general directions to UIDAI to ensure future residents facing technical errors are provided written remedial procedures, facilitation mechanisms, and a citizen-centric approach to prevent avoidable litigation. Rule was made absolute with no order as to costs.
¶ 26, 28Original Court PDF
Rohit Bandu Nikalje And AnrvsThe Regional Officer, Uidai, Mumbai Regional Office And Ors
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