4. Violations of Natural Justice and the Right of Due Process Such an approach could have confirmed identity even where there were inconsistencies beyond just the name. Consider the case where Justice B.K. Sharma doubted whether Jaynal Seikh and Jaynal Ali referred to the same individual.409 A key factor in this finding was that Jaynal Ali appeared alongside his daughter, Jeleka Begum, and her husband in the 1997 Voter Roll for Karagari Nonke Village, whereas Jaynal Seikh had been listed as a voter in Gadeshalipam Village in the 1965 and 1970 Voter Rolls. Justice Sharma pointed to the absence of any evidence that Jeleka’s father had shifted residence. However, even a simple review of the circumstances suggests that Karagari Nonke might well have been Jeleka Begum’s matrimonial home, to which her father relocated later in life. A straightforward clarification could have resolved this issue, yet the Court did not seek one. Notably, the emphasis on the address discrepancy appears to have been used mainly to reinforce an already drawn conclusion—namely, that the variation in title (Seikh versus Ali) meant the two names referred to different people. As explained earlier, had the title variation been treated as immaterial—as it should have been—the difference in address would have similarly lost its significance. In fact, in Sirajul Hoque v. State of Assam,410 the Supreme Court of India reversed the finding that Sirajul Hoque was a foreigner by adopting a holistic reading of the evidence, as advocated above. Sirajul Hoque sought to establish his citizenship by proving that his grandfather had resided in Assam before 1971. His grandfather appeared as Kefatullah in the 1966 and 1970 Voter Rolls for Village Sotobashjani. His father, however, was recorded as Hakim Ali, son of Kematullah, in the 1997 Voter Roll for Village Sagolchora. 124 The FT accepted that Sirajul Hoque was indeed the son of Hakim Ali, but held that he had failed to prove that Hakim Ali was the son of Kefatullah of the 1966 and 1970 Voter Rolls. The Tribunal refused to infer that Kematullah and Kefatullah referred to the same person, citing the spelling difference in the names and the discrepancy between the villages where the father and projected grandfather were recorded as voters. This, in the Tribunal’s view, created doubt about the linkage Sirajul Hoque sought to establish. The Supreme Court, however, disagreed. Justice R.F. Nariman held that the minor spelling variation between Kematullah and Kefatullah was inconsequential, especially in light of the consistent details found in other particulars—such as the names of the great-grandfather and other family members— which reinforced the connection. Justice Nariman further noted that the mere fact that Hakim Ali was recorded as a voter in a different village from his father did not justify rejecting the document, as relocation over time is common and should not cast doubt on identity without concrete contrary evidence. 409 410 Jeleka Begum (n 394). Sirajul Hoque (n 384).