Mental Capacity, Not Just Age, Determines Legal Consent: Supreme Court Orders Repatriation of Disabled US Citizen to His Mother

A Person Functioning at the Level of an 8-Year-Old Cannot Be Expected to Make Legally Binding Decisions – In a landmark decision Supreme Court of India overturned the Madras High Court’s ruling and ordered the immediate repatriation of Aadith Ramadorai, a 22-year-old US citizen with Ataxic Cerebral Palsy, to the United States under the legal guardianship of his mother, Sharmila Velamur. The Court ruled that Aadith lacked the cognitive ability to make legally binding decisions and held that the High Court had failed in its duty by relying solely on Aadith’s verbal responses rather than expert medical evaluations.

"The law does not presume legal competence solely based on age. Where a person’s cognitive abilities are significantly impaired, their consent cannot be inferred in matters of long-term welfare," the Court observed.

Aadith Ramadorai, born in Idaho, USA, was diagnosed with Ataxic Cerebral Palsy and moderate intellectual disability. His parents, both US citizens, divorced in 2007, and the Idaho District Court granted them joint legal custody of their two sons. As he grew older, it became evident that Aadith would require a legal guardian due to his developmental disabilities.

In June 2022, his mother, Sharmila Velamur, filed a Guardianship Petition before the Idaho Court, seeking full and permanent guardianship over Aadith. His father, V. Sanjay, opposed the petition, arguing that Aadith was capable of making independent decisions about his life.

While the Idaho Court was still deliberating, Sanjay removed Aadith from the US on December 31, 2023, without informing Sharmila. For several weeks, Sharmila had no contact with her son and later discovered that he was in Chennai, India, residing with his father and paternal grandparents.

The Idaho Court ruled in favor of Sharmila, issuing an Emergency Order on February 22, 2024, directing Aadith to return to the US within 72 hours. When this order was not complied with, the court granted Sharmila full and permanent guardianship on April 9, 2024.

Despite the Idaho Court’s ruling, Aadith remained in India, prompting Sharmila to file a habeas corpus petition before the Madras High Court. However, the High Court dismissed the petition, stating that Aadith had expressed his desire to stay in India.

"The High Court failed to assess whether Aadith had the mental capacity to make an informed choice. A few minutes of oral interaction cannot replace a thorough judicial inquiry into his cognitive abilities," the Supreme Court remarked.

The Supreme Court carefully examined extensive medical assessments from multiple institutions, including NIMHANS, Bengaluru, the Institute of Mental Health, Kilpauk, and the Idaho Department of Health and Welfare. The Court found that these expert reports clearly established that Aadith’s cognitive abilities were equivalent to those of an 8-to-10-year-old child."The right to autonomy does not extend to decisions that an individual lacks the capacity to comprehend. Where a person is found to have severe cognitive limitations, their consent must be weighed against expert medical evaluations," the Court held.

The Comprehensive Assessment Report from NIMHANS, Bengaluru concluded that Aadith suffered from significant intellectual impairment, lacked financial and social decision-making abilities, and would require lifelong external support for higher-level decisions. His full-scale IQ was measured at 53, placing him in the very low range of cognitive ability, and his overall disability was classified at 80%.

"The findings are unambiguous: Aadith is incapable of making legally binding decisions about his long-term welfare. Courts must prioritize objective medical evidence over superficial assessments of consent," the Supreme Court asserted.

Criticism of the Madras High Court’s Approach

The Supreme Court strongly criticized the Madras High Court’s handling of the case, stating that it dismissed Sharmila’s habeas corpus petition without engaging with the extensive medical evidence.

"The High Court decided a question of immense complexity in a shockingly simplistic manner. Instead of assessing Aadith’s cognitive capacity, it relied purely on his verbal responses during a brief courtroom interaction," the Court observed.

The High Court had ignored crucial reports from the Idaho Department of Health and Welfare, which had already determined that Aadith lacked the ability to live independently and required structured care.

"When the matter involves a person with a severe intellectual disability, a court must act with caution and diligence. A casual verbal exchange with the individual cannot substitute for a structured medical and legal inquiry into their decision-making abilities," the Supreme Court emphasized.

Parens Patriae Doctrine and the Best Interests of Aadith

The Supreme Court invoked the parens patriae doctrine, which empowers courts to act in the best interests of individuals who cannot make decisions for themselves. Applying this principle, the Court concluded that Aadith’s welfare would be best served in the US, where he had access to superior healthcare, structured education, and social security benefits.

"Aadith’s return to the United States is not merely a matter of parental preference—it is a necessity for his continued care and development. The infrastructure available to him there is far superior to what he currently receives in India," the Court ruled.

The Supreme Court noted that Aadith’s younger brother, who also has a developmental disability, was residing in the US with Sharmila and had access to structured special education programs and disability benefits. Aadith himself had expressed a desire to return to the US and continue his education.

The Supreme Court set aside the Madras High Court’s ruling and issued a binding directive for Aadith’s repatriation to the United States.

"In light of the overwhelming evidence, there is no doubt that Aadith’s best interests lie in his return to the United States, where his legal and medical rights are best protected," the Court declared.

The Court ordered Indian authorities to ensure that Aadith was placed under the guardianship of his mother and that all necessary travel arrangements were facilitated for his return to the US.

"Legal majority does not mean absolute capacity. When a person functions at the level of an 8-year-old, their stated preference cannot override an objective assessment of their long-term welfare," the Supreme Court concluded.

This decision sets a vital precedent in international guardianship and disability rights cases, reaffirming that mental capacity, not just age, determines legal competence.

Date of Decision: 04/03/2025