Context: Several Indian states have raised their COVID-19 death toll sharply higher after the discovery of thousands of unreported cases.

• It is lending weight to suspicion that India’s overall death tally is significantly more than the official figure.

Undercounting of COVID-19 deaths in India

• Over the last month, Indian journalists from across the country have accessed and reported on State-level all-cause mortality from the Civil Registration System (CRS), currently confidential and closed to the public. 
• This data has been able to show a large rise in excess mortality in the surge months of the second wave of April and May 2021 in particular.
• For example, the numbers for Madhya Pradesh show over 1.18 lakh excess deaths in 2021, which is over 26 times the official COVID-19 death toll for the same period. 
• The other States too show excess mortality in 2021 even assuming full registration.

Sources of error

• Underestimates of total mortality: The Union government last published annual Civil Registration System data for 2019. 
• This data shows that India registered 92 of every 100 deaths as of 2019, but there was large variation between States. Bihar, for instance, registered just half of all deaths. 
• Additionally, the data currently available on State-level CRS portals (behind a login) miss even more deaths. 

Mortality was either naturally increasing over time, or if registration was getting better, or if both were taking place: If any of these three phenomena were taking place, the magnitude of excess mortality in 2020 and 2021 could be moderated by these processes.

• On the first count, total estimated mortality (registered deaths plus those that are not registered) has actually been declining since 2013 according to the CRS. 
• The increase in registered deaths will not continue at the same pace in all States — once States begin to achieve full registration, increases should be more modest. 
• In Madhya Pradesh, for instance, the level of death registration improved by over 21 percentage points between 2017 and 2019 to reach 89% in 2019. 

Suggestion

• Improving registration of deaths: While the total number of deaths in India during the pandemic reported using Civil Registration System data might be an underestimate, a part of the increase in mortality can be explained by improved registration. 
• Rectifying errors: While this data remains the best source of data on all-cause mortality, its continued use will require careful work on account of some known sources of error that exist with the data.
• The Civil Registration System is an imperfect system. Acknowledging the gaps in the system will help journalists, but does not minimise the magnitude of the crisis.

Civil Registration System (CRS) 

• Civil Registration System (CRS) in India is the unified process of continuous, permanent, compulsory and universal recording of the vital events (births, deaths, stillbirths) and characteristics thereof. 
• It is a Continuous, Permanent and Systematic recording of births and deaths obtained under the Registration of Births and Deaths Act, 1969.
• The data generated through a complete and up-to-date CRS is essential for socio-economic planning.
• The CRS moved online relatively recently (between five and three years ago in most States), and State-level portals now display data for every day from January 1, 2018 to the present day. 

Registration of Birth and Death rules 1969

• The registration of births, deaths and still births are compulsory, in all parts of the Country.
• The normal period of 21 days (from the date of occurrence) has been prescribed for reporting the birth, death and still birth events.
• If the event of a birth or death is reported for registration to the prescribed authority within the normal period of 21days, no fee would be charged.
• The responsibilities for reporting the events have been prescribed separately for domiciliary events as well as Institutional events:
• In respect of birth or death occurred in a house, it is the duty of the Head of the house/household or nearest relative of the head present in the house or in the absence of any such person, the oldest male person present therein during the said period is responsible to report the event to the concerned Registrar/ sub Registrar.
• These events can also be reported through the prescribed Notifiers such as Anganwadi Workers, ANM’s, ASHA’s and others.
• In respect of birth or death that occurred in a hospital, health centre, Maternity or nursing home or other such institutions, the medical officer In-charge or any person authorized by him on this behalf is responsible for reporting.
• Under the provision of Section 7 of the RBD Act, the Registrars of Births and Deaths are appointed for each local area comprising the area within the jurisdiction of the Municipality, Panchayat or other local authority.
• The Sub- Registrars are also appointed under section 7(5) of the Act and assigned to them any or all powers of Registrars.
• The Registrars / Sub Registrars are deemed to be the public servant under section 21 of the Indian Penal Code.

In Rural areas following have been appointed as Registrar of Births and Death

• Panchayat Secretaries/Karmi/Gram Sevak in 15 States and 3 UTs.
• Medical Officer In-charge or equivalent in 7 States and 3 UTs– (Assam, Haryana, Meghalaya, Orissa, and Punjab, Sikkim, Manipur (Partly), A & N Island, Delhi and Lakshadweep)
• Village Accountants / Village Administrative Officers in 2 States - Karnataka and Tamil Nadu.
• SHO/Police Officials in Jammu & Kashmir and Chandigarh UT (Rural).
• School Teachers in Mizoram and Nagaland. Circle Officer/Village Level Workers in Arunachal Pradesh.

In Urban Areas: The Municipal Health Officer, Health Officer or Equivalent Officers are appointed as Registrar of births and deaths.

• In case, any child born outside India, his/her birth would be registered under the Citizenship Act 1955 and Citizens (Registration at Indian consulates) Rules, 1956 at the Indian Missions.
• However, under Section 20 of the RBD Act, if the parents of the child return to India with a view to settling therein, the said birth can be registered within sixty days from the date of arrival of the child in India at the place of settling.

If this birth cannot be registered within 60 days, the same can be registered under the delayed registration provisions.

By: Shubham Tiwari