Baidehi Behera vs State Of Odisha And Others on 6 August, 2026

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    Orissa High Court

    Baidehi Behera vs State Of Odisha And Others on 6 August, 2026

    Author: B.P. Routray

    Bench: B.P. Routray

                                                                                                     WP(C)/4157/2026
    Signature Not Verified                                                                          ODHC010086102026
    Digitally Signed                                                                                   2026:OHC:13
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.
    Date: 06-Aug-2026 17:14:07
    
    
    
                                 IN THE HIGH COURT OF ORISSA AT CUTTACK
    
                                                W.P.(C) No.4157 of 2026
                                               CNR NO.ODHC010086102026
                         (In the matter of an application under Article 226 & 227 of the
                         Constitution of India)
    
                         Baidehi Behera                                   ...                      Petitioner
    
                                                               -versus-
    
    
                         State of Odisha and others                       ...              Opposite Parties
    
                         Advocate(s) appeared in this case:-
    
                                       For Petitioner            : Mr.M.Faradish, Advocate
    
                                       For Opposite Parties      : Mr.T.K.Dash, AGA
                                                                   Mrs.M.Tripathy, Advocate
                                                                   (for O.P.No.3 & 4)
    
                                            CORAM: JUSTICE B.P. ROUTRAY
    
                                                          JUDGMENT
    

    ———————————————————————————

    Date of Hearing : 2nd July, 2026
    Date of Judgment : 6th August, 2026

    SPONSORED

    ———————————————————————————
    B.P. Routray, J.

    1. Present writ petition is directed assailing the order of the Chief

    Manager, State Bank of India at Karanjia Branch (O.P.No.4) rejecting

    the prayer for settlement of claim of her deceased husband due to

    error in date of death in the Death Certificate.

    W.P.(C) No.4157 of 2026 Page 1 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    2. The Petitioner namely, Baidehi Behera is the wife of Rabindra

    Nath Behera, whose death has been declared as civil death by the

    decree of learned Civil Court dated 27th February 2024. Late Rabindra

    Nath Behera was serving as Head Messenger at State Bank of India in

    Karanjia Branch. On 10th December 2007 after office hour he did not

    return to his house and went missing. Consequently, present

    Petitioner, being the wife, lodged missing FIR at Karanjia Police

    Station vide MMR No.7 dated 12th December 2007. The Petitioner

    and other family members of late Rabindra Nath Behera searched for

    him to their best leaving no stone unturned to get trace of Rabindra

    Nath Behera, and in the meanwhile, around fifteen years passed away.

    The Petitioner then filed C.S.No.162 of 2022 in the Court of the

    learned Civil Judge (Sr.Division), Karanjia praying to declare

    Rabindra Nath Behera as civil death. The learned Civil Court vide

    decree dated 27th February 2024 decreed the suit declaring that

    Rabindra Nath Behera is dead and civil death of Rabindra Nath

    Behera stands declared. Then on the application of the Petitioner and

    based on the declaration of learned Civil Court, the Department of

    Health and Family Welfare of Karanjia NAC issued the Certificate of

    Death in terms of Section 12/17 of the Registration of Births and

    W.P.(C) No.4157 of 2026 Page 2 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    Deaths Act and Rules stating the date of death of Rabindra Nath

    Behera on 10th December 2007.

    3. The Petitioner applied for settlement of her claim with the Bank

    authority along with all required documents, and finally Opposite

    Party No.4, i.e. the Chief Manager vide his letter dated 15th November

    2025 rejected the prayer of the Petitioner for settlement of claim of the

    deceased on the ground that the date of death of deceased recorded in

    the Death Certificate is erroneous and further advised to correct the

    same before the appropriate authority. As per the memorandum

    attached to the letter dated 15th October 2025 (Annexure-5) of

    Opposite Party No.4, it is mentioned that the Registrar erroneously

    mentioned the date of missing as the date of death, which is not

    legally correct. It is important to reproduce the relevant portion of the

    said memorandum, which has been formed as part of rejection letter

    of the authority.

    “2. It is observed that Shri Rabindra Nath Behera has been
    missing since 10.12.2007. Long after completion of statutory
    period of seven years, his family members approached the
    competent Civil Court. The Civil Court, vide judgment and decree
    dated 27.02.2024, declared Shri Behera to be “civilly death” in
    accordance with Section 108 of the Evidence Act,1872. Based on
    the Court’s order, the Registrar of Births and Deaths issued a

    W.P.(C) No.4157 of 2026 Page 3 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    Death Certificate. However, the Registrar erroneously mentioned
    the date of missing 10.12.2007 as the sustainable date.

    3. As held in LIC of India v. Anuradha (104), the presumption
    of death applies only to the fact of death, not to the exact date. In
    absence of contrary proof the date of death is reckoned from the
    date of the Court’s declaration. Hence, the legally date of death is
    27.02.2024, not 10.12.2007. The Registrar has erroneously
    recorded the “date of missing” as the “date of death” under Section
    15
    of the Registration of Birth and Deaths Act, 1969, such an error
    can be corrected by the Registrar/Chief Registrar on application
    with the Court order if refused, the remedy lies before the Chief
    Registrar/High Court.

    4. In light of the above, the date of death of Shri Behera
    should be treated as 27.02.2024, i.e. the date of declaration by the
    Civil Court. The entry made by the Registrar mentioning
    10.12.2007 as the date of death is legally unsustainable and
    requires rectification. The concerned legal heirs may immediately
    file an application under Section 15 of the Registration of Births
    and Deaths Act, 1969, enclosing the certified copy of the Civil
    Court’s judgment dated 27.02.2024, for correction of the death
    register and issuance of a fresh death certificate. If such application
    is not allowed, the remedy lies before the Chief Registrar /High
    Court for appropriate directions.”

    4. The Petitioner challenges such communication made by the

    authority rejecting her claim for settlement of claim of deceased

    Rabindra Nath Behera by stating that the Bank Aauthority, who was

    the employer of the deceased Rabindra Nath Behera, does not possess

    any authority to say that the Registrar of Births and Deaths has

    W.P.(C) No.4157 of 2026 Page 4 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    erroneously recorded the date of death as such, and he has no

    authority to dispute the date of death mentioned in the Death

    Certificate, which is a public document.

    5. It is submitted on behalf of the Petitioner that in the matter of

    civil death, after declaration of the Court to that effect, all such

    presumptions as to the actual date of death are closed resting on the

    date of death declared by the statutory authority i.e. the Registrar of

    Births and Deaths. It would be grossly illegal to accept any other date

    of death than the date mentioned in the Death Certificate issued by the

    competent statutory authority. It is submitted on behalf of the

    Petitioner that the declaration made by the learned Civil Court in case

    of civil death is done after completion of the statutory period and the

    provisions of the Indian Evidence Act or Bharatiya Sakshya

    Adhiniym do not prescribe any such date to be presumed as the date

    of death.

    6. Per contra, it is submitted on behalf of the Bank-Opposite

    Parties that in the matter of civil death, the same is required to be

    declared by the decree of Civil Court and thus no such death prior to

    the date of declaration by the Court could be construed as the date of

    death. The Opposite Parties, in this regard, relies on the decision of

    W.P.(C) No.4157 of 2026 Page 5 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    LIC of India vrs. Anuradha, (2004) 10 SCC 131 to support their

    stand.

    7. In the case at hand, the admitted facts remain that Rabindra

    Nath Behera went on missing since 10th December 2007. The missing

    report was lodged before the police on 12th December 2007 and

    learned Civil Court declared civil death of Rabindra Nath Behera by

    decree dated 27th February 2024. It is also admitted that the Death

    Certificate, in terms of the provisions of Registration of Births and

    Deaths Act, 1969 and the Rules thereof, has been issued on 24th July

    2007 stating the date of death on 10th December 2007. Thus, the only

    dispute remains to be adjudicated is whether the date of death of

    deceased Rabindra Nath Behera to be accepted from the date of

    missing as mentioned in the Death Certificate or to be treated from the

    date of declaration made by the learned Civil Court in the decree.

    8. On the backdrop of the controversy and in view of the admitted

    facts, the questions fall for determination are, whether the employer

    (Bank) can question the recorded date of birth in the Death Certificate

    as erroneous to deviate from the same and secondly, what would be

    the acceptable date of death in the matter of civil death.

    W.P.(C) No.4157 of 2026 Page 6 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    9. Section 8 of the Registration of Births and Deaths Act requires

    registration of the births and deaths and Section 12 entitles the

    informant to get copy of extract of Register of Births and Deaths in

    the prescribed particulars. Further, Section 17 specifies that all such

    extracts given shall be certified by the Registrar or any other Officer

    authorized on their behalf and shall be admissible in evidence for the

    purpose of proving the birth and death to which the entry relates. In

    the case at hand, the Death Certificate dated 24th July 2024

    (Annexure-2) issued vide Registration No.280/2024 is never

    challenged, as on date, by any authority or any person including the

    Opposite Parties. Issuance of Death Certificate, in terms of the

    statutory provisions of Registration of Births and Deaths Act and

    Rules, is left unquestioned. But, the Bank-Opposite Parties being the

    employer of the deceased refused to accept recording of such date of

    death in the Death Certificate on the ground that the same is erroneous

    and further advised the Petitioner to correct the same. Section 15 of

    Registration of Births and Deaths Act prescribes the provisions for

    correction of entry of birth or death in the register, appearing

    erroneous to the satisfaction of the Registrar, either to correct it or to

    cancel it. Section 15 reads as follows:

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    Signature Not Verified
    Digitally Signed

    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    “15. Correction or cancellation of entry in the register of
    births and deaths.-If it is proved to the satisfaction of the
    Registrar that any entry of a birth or death in any register kept
    by him under this Act is erroneous in form or substance, or has
    been fraudulently or improperly made, he may, subject to such
    rules as may be made by the State Government with respect to
    the conditions on which and the circumstances in which such
    entries may be corrected or cancelled, correct the error or cancel
    the entry by suitable entry in the margin, without any alteration
    of the original entry, and shall sign the marginal entry and add
    thereto the date of the correction or cancellation.”

    Therefore, it is only the Registrar who is authorized to correct any

    entry made in the register of births and deaths upon his satisfaction

    and no one else.

    10. The provisions of the Indian Evidence Act or the Bharatiya

    Sakshya Adhiniyum attach the presumption of correctness and

    genuineness of the public documents.

    11. In Uli Bewa vrs. Mana Bewa, I.L.R. 1963 Cuttack 451, this

    Court has held that Death Register by Municipality comes within the

    definition of a public document under Section 74 of the Evidence Act

    and the entries therein could be proved by production of certified

    copies under Section 77 of the Evidence Act. The document is

    therefore by itself a piece of evidence admissible under Section 35 of

    W.P.(C) No.4157 of 2026 Page 8 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    the Evidence Act. There is a presumption under Section 114 of the

    Evidence Act that the entry was properly made by a public servant in

    discharge of his official duty and formal proof of the fact that a

    particular officer made the entry is not necessary.

    12. In Gopichand Arya vrs. Smt.Bedamo Kuer, AIR 1966 Patna

    231, it is stated that the Death Certificate is the most important

    document to prove the date of death since the entry was made by a

    public servant in due discharge of his official duty. This being a

    public document, presumption of correctness is attached to it and

    therefore heavy onus lies on the party who wants to discharge the

    onus.

    13. In the present case at hand, the Death Certificate at Annexure-2

    is left unchallenged as on date and as per the submissions of the

    Petitioner, the same has been accepted by the LIC of India as correct,

    to release the death benefits in favour of the dependants. Further, said

    Death Certificate at Anenxure-2 stands genuine till date as it is, to

    presume the correctness in respect of the entries made therein,

    particularly regarding the date of death of the deceased. Therefore, no

    option lies with the Bank-Opposite Parties to dispute the date of death

    to describe the same as erroneous against such entry made in the

    W.P.(C) No.4157 of 2026 Page 9 of 16
    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    Death Certificate. As stated earlier, such power remains with the

    Registrar only, to make any correction in respect of any entry in the

    Register of Births and Deaths in terms of Section 15 of the Act and no

    other authority is authorized to discard the same as unacceptable or to

    say as an erroneous entry.

    14. In LIC of India vrs. Anuradha (supra), the issue arose before

    the Hon’ble Supreme Court relating to payment of life insurance

    benefits concerning non-payment of premium from the date of

    missing of the insured whose civil death was declared subsequently.

    The Hon’ble Supreme Court has explained that when an issue arises

    as to the date or time of death, the same shall have to be determined

    on evidence, direct or circumstantial, and not by assumption or

    presumption. The relevant observations of the Hon’ble Supreme

    Court in the said decision are reproduced below:

    “2. A common question of law centering around Sections
    107
    and 108 of the Indian Evidence Act, 1872 arises for
    decision in these two appeals.

    xxx xxx xxx

    12. Neither Section 108 of the Evidence Act nor logic, reason
    or sense permit a presumption or assumption being drawn or
    made that the person not heard of for seven years was dead
    on the date of his disappearance or soon after the date and
    time on which he was last seen. The only inference
    permissible to be drawn and based on the presumption is that

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    Signature Not Verified
    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    the man was dead at the time when the question arose subject
    to a period of seven years’ absence and being unheard of
    having elapsed before that time. The presumption stands
    unrebutted for failure of the contesting party to prove that
    such man was alive either on the date on which the dispute
    arose or at any time before that so as to break the period of
    seven years counted backwards from the date on which the
    question arose for determination. At what point of time the
    person was dead is not a matter of presumption but of
    evidence, factual or circumstantial, and the onus of proving
    that the death had taken place at any given point of time or
    date since the disappearance or within the period of seven
    years lies on the person who stakes the claim, the
    establishment of which will depend on proof of the date or
    time of death.

    13. A presumption assists a party in discharging the burden
    of proof by taking advantage of presumption arising in his
    favour dispensing with the need of adducing evidence which
    may or may not be available. Phipson and Elliott have
    observed in Manual of the Law of Evidence (11th Edn., at p.

    77) that although there is almost invariably a logical
    connection between basic fact and presumed fact, in the case
    of most presumptions it is by no means intellectually
    compelling. In our opinion, a presumption of fact or law,
    which has gained recognition in statute or by successive
    judicial pronouncements spread over the years, cannot be
    stretched beyond the limits permitted by the statute or
    beyond the contemplation spelled out from the logic, reason
    and sense prevailing with the judges, having written opinions
    valued as precedents, so as to draw such other inferences as
    are not contemplated.

    W.P.(C) No.4157 of 2026 Page 11 of 16
    Signature Not Verified
    Digitally Signed

    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    14. On the basis of the abovesaid authorities, we
    unhesitatingly arrive at a conclusion which we sum up in the
    following words: the law as to presumption of death remains
    the same whether in the common law of England or in the
    statutory provisions contained in Sections 107 and 108 of the
    Indian Evidence Act, 1872. In the scheme of the Evidence
    Act
    , though Sections 107 and 108 are drafted as two sections,
    in effect, Section 108 is an exception to the rule enacted in
    Section 107. The human life shown to be in existence, at a
    given point of time which according to Section 107 ought to
    be a point within 30 years calculated backwards from the
    date when the question arises, is presumed to continue to be
    living. The rule is subject to a proviso or exception as
    contained in Section 108. If the persons, who would have
    naturally and in the ordinary course of human affairs heard of
    the person in question, have not so heard of him for seven
    years, the presumption raised under Section 107 ceases to
    operate. Section 107 has the effect of shifting the burden of
    proving that the person is dead on him who affirms the fact.
    Section 108, subject to its applicability being attracted, has
    the effect of shifting the burden of proof back on the one who
    asserts the fact of that person being alive. The presumption
    raised under Section 108 is a limited presumption confined
    only to presuming the factum of death of the person whose
    life or death is in issue. Though it will be presumed that the
    person is dead but there is no presumption as to the date or
    time of death. There is no presumption as to the facts and
    circumstances under which the person may have died. The
    presumption as to death by reference to Section 108 would
    arise only on lapse of seven years and would not by applying
    any logic or reasoning be permitted to be raised on expiry of
    6 years and 364 days or at any time short of it. An occasion

    W.P.(C) No.4157 of 2026 Page 12 of 16
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    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    for raising the presumption would arise only when the
    question is raised in a court, tribunal or before an authority
    who is called upon to decide as to whether a person is alive
    or dead. So long as the dispute is not raised before any forum
    and in any legal proceedings, the occasion for raising the
    presumption does not arise.

    15. If an issue may arise as to the date or time of death the
    same shall have to be determined on evidence, direct or
    circumstantial, and not by assumption or presumption. The
    burden of proof would lie on the person who makes assertion
    of death having taken place at a given date or time in order to
    succeed in his claim. Rarely may it be permissible to proceed
    on the premise that the death had occurred on any given date
    before which the period of seven years’ absence was shown
    to have elapsed.

    16. We cannot, therefore, countenance the view taken by the
    High Court in either of the two appeals that on the expiry of
    seven years by the time the issue came to be raised in the
    Consumer Forum or civil court and evidence was adduced
    that the person was not heard of for a period of seven years
    by the wife and/or family members of the person then not
    only could the death be presumed but it could also be
    assumed that the presumed death had synchronised with the
    date when he was reported to be missing or that the date and
    time of death could be correlated to the point of time
    coinciding with the commencement of calculation of seven
    years backwards from the date of initiation of legal
    proceedings. In order to successfully maintain the claim for
    benefit under the insurance policies, it is necessary for the
    policy to have been kept alive by punctual payment of
    premiums until the claim was made. The appellant LIC was
    justified in turning down the claims by pleading that the

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    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    policies had lapsed and all that could be paid to the claimants
    was the paid-up value of the policies.”

    15. In the instant case at hand, the deceased went missing on 10 th

    December 2007, the civil suit for declaration of civil death was filed

    on 16th July 2022 and decreed on 27th February 2024. As explained

    in the decision of LIC of India vrs. Anuradha (supra), the question

    of time of death is a question of facts, to be determined by evidence,

    factual or circumstantial and not a presumption. Section 108 of the

    Indian Evidence Act reads that, “Burden of proving that person is

    alive who has not been heard of seven years – provided that when

    the question is whether a man is alive or dead and it is proved that

    he has not been heard of for seven years by those who would

    naturally have heard of him if he had been alive, the burden of

    proving that he is alive is shifted to the person who affirms it.”

    Thus, after declaration of civil death by decree of the Civil Court,

    the statutory competent authority, i.e. the Registrar of Births and

    Deaths, has issued the Death Certificate under Annexure-2

    mentioning the date of death on 10th December 2007.

    16. As stated earlier, the Death Certificate issued under

    Annexure-2 is undisputedly a public document. The Hon’ble

    W.P.(C) No.4157 of 2026 Page 14 of 16
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    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    Supreme Court in Birad Mal Singhvi vrs. Anand Purohit, AIR

    1988 (SC) 1796, have held at para-3(a) that;

    “3 (a) To render a document admissible under Section 35 of
    the Evidence Act, three conditions must be satisfied, firstly,
    entry that is relied on must be one in a public or other official
    book, register or record, secondly, it must be an entry stating
    a fact in issue or relevant fact; and thirdly, it must be made
    by a public servant in discharge of his official duty, or any
    other person in performance of a duly specially enjoined by
    law.”

    17. Here, the Death Certificate at Annexure-2, issued as per the

    statutory provisions of the Registration of Births and Deaths Act

    and Rules made thereof, is an unchallenged and unquestioned

    document and therefore, the entries made therein are duly proved on

    production of certified copy of the same. Such entries made in the

    Death Certificate are binding on all such persons and authorities.

    So, the Bank-Opposite Parties are prohibited to dispute such entries

    made in the Death Certificate without having jurisdiction in that

    respect. It is not that the Bank-Opposite Parties are producing any

    material evidence to deny the date of death mentioned in the Death

    Certificate, but simply denies to accept such date of death. This is

    impermissible on the part of the Bank Authority. It is stated here

    that such entries made in the Death Certificate under Annexure-2 in

    W.P.(C) No.4157 of 2026 Page 15 of 16
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    Digitally Signed
    Signed by: CHITTA RANJAN BISWAL
    Reason: Authentication
    Location: Orissa High Court, Cuttack.

    Date: 06-Aug-2026 17:14:07

    terms of the statutory provisions relating to it, is binding on the

    Bank Authority.

    18. For the reasons stated above, the writ petition is allowed and the

    impugned order dated 15th October 2025 under Annexure-5 along

    with the attachments is set aside. Opposite Parties No.3 & 4 are

    directed to release the claim of settlement of late Rabindra Nath

    Behera in favour of the Petitioner within a period of two months from

    today, if no other legal impediment is there.

    (B.P. Routray)
    Judge

    C.R.Biswal, A.R.-cum-Sr.Seretary

    W.P.(C) No.4157 of 2026 Page 16 of 16



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