Bombay High Court

Mandamus lies to compel UIDAI to facilitate fresh enrollment for residents facing technical biometric mismatches.

Rohit Bandu Nikalje And Anr vs The Regional Officer, Uidai, Mumbai Regional Office And Ors

Bombay High CourtJUDGMENT: May 06, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioners, 19-year-old twin brothers, were issued Aadhaar cards as minors in 2012.

Source reference: para. 3

Upon attaining the age for mandatory biometric updates in 2022, they submitted the required data, but their requests were rejected due to "biometric mismatch".

Source reference: para. 3-4

Over 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.

Source reference: para. 4-6

Consequently, as students, they faced prejudice in higher education admissions and insurance coverage.

Source reference: para. 5

They approached the High Court seeking a mandamus for the biometric update or issuance of fresh Aadhaar cards.

Source reference: para. 3
02

Issues

1. Whether a statutory authority can leave a resident in administrative limbo without a clear remedial pathway in cases of biometric mismatch.

Source reference: para. 12

2. Whether the Petitioners are entitled to fresh enrollment or biometric rectification under the Aadhaar Act and Regulations despite existing record anomalies.

Source reference: para. 17
03

Law 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.

Source reference: para. 10

Regulations 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.

Source reference: para. 11

Justice K.S. Puttaswamy (Retd.) v. Union of India, emphasizing that Aadhaar must operate within constitutional limits of proportionality and exclusion safeguards.

Source reference: para. 13

Comptroller 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.

Source reference: para. 15
04

Reasoning

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".

Source reference: para. 12

The Court found that the Petitioners, having no allegations of fraud against them, were victims of inconsistent administrative communication.

Source reference: para. 16

It held that under Regulation 31, if an Aadhaar number is omitted, the individual has a right to re-enroll.

Source reference: para. 11

The 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.

Source reference: para. 14, 17

The Court invoked the maxim lex non cogit ad impossibilia, noting Petitioners cannot be expected to cure system-level mismatches except through prescribed UIDAI mechanisms.

Source reference: para. 18
05

Holding

The Court allowed the Writ Petition, directing the Petitioners to submit fresh applications for Aadhaar enrollment within fifteen days.

The 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.

Source reference: para. 19-20

The 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.

Source reference: para. 26, 28
Bombay High Court

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Rohit Bandu Nikalje And AnrvsThe Regional Officer, Uidai, Mumbai Regional Office And Ors

Bombay High Court · May 06, 2026

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