SC rejects judge's date of birth change; horoscope notebook with PIN code exposes inconsistency

The Supreme Court has dismissed a plea by a Tamil Nadu judicial officer to change his date of birth, pointing to serious inconsistencies in the evidence he submitted. The officer, M. Manickam, had sought to alter his recorded birth date from March 19, 1947, to November 24, 1950, which would have extended his service by nearly four years.

Manickam joined the Tamil Nadu State Subordinate Judicial Services as Munsif-cum-Judicial Magistrate in November 1988. In October 1993, he submitted a representation to the Chief Judicial Magistrate, Kanniyakumari, claiming that his actual date of birth was different from what was recorded in his SSLC certificate. Over time, he obtained favourable orders from various courts, including the Madras High Court, which ruled in his favour. The Registrar General of the Madras High Court then moved the Supreme Court challenging that decision.

One of the key objections raised by the Registrar General was that Manickam had submitted his representation after completing five years of service. Under the Tamil Nadu State Judicial Service Rules, any request for change of date of birth must be made within five years of joining service. The Supreme Court agreed with this objection. However, the bench of Justices Mukundakam Sharma and Anil R. Dave also examined the other grounds raised in the appeal.

The court noted that Manickam's SSLC certificate originally showed March 19, 1947, as his date of birth. Later, the entry was changed to November 24, 1950, but the alteration was made without any official seal or date. The judges refused to accept the changed entry, observing that it appeared to have been done by someone merely putting his initials without proper authentication.

The court also scrutinised a medical certificate submitted by Manickam. The certificate, issued by a doctor, stated: “According to my physical examination and personal of his appearance of the individual, he appears to be about 48 years (Forty Eight years) according to his own statement.” The judges called this certificate vague and unreliable, noting that it did not mention any radiological examination or ossification test. They emphasised that there must be strong, cogent and reliable evidence to support a claim that the date of birth was wrongly entered due to a mistake.

Perhaps the most telling evidence against Manickam was a horoscope notebook. The judges examined it closely and found that although it was claimed to contain horoscopes of all the sons and daughters of Manickam's father, written at different times between 1939 and 1953, all the entries appeared to have been made at one go by the same person using the same ink. “A bare perusal of the document would indicate that all the horoscopes are made at one point of time by the same person at one go and not on different dates as sought to be claimed,” the court observed. Additionally, the notebook contained a PIN code, a detail that stood out as anachronistic for the period it supposedly covered.

In light of these findings, the Supreme Court dismissed Manickam's claim, setting aside the orders of the lower courts that had allowed the change of date of birth. The judgment reinforces the principle that claims to alter official records, especially date of birth, must be supported by credible and trustworthy evidence.