The Andhra Pradesh High Court has enhanced compensation payable to the family of a deceased tractor driver from ₹50,000 to ₹5 lakh, holding that the Motor Vehicles Act is a welfare legislation meant to provide just relief to victims and their dependants. The Court ruled that a claim under Section 163-A of the Motor Vehicles Act cannot be rejected merely because the deceased himself was allegedly negligent in causing the accident.
Background of the Case
The appeal arose from an award passed by the Motor Accidents Claims Tribunal in Nellore, which had granted only ₹50,000 to the deceased driver's wife and son after concluding that the accident occurred due to his own negligence. The family had originally sought compensation of ₹5 lakh following the fatal tractor accident in August 2012.
Before the High Court, the appellants argued that the Tribunal had failed to apply the beneficial provisions of the Motor Vehicles Act and had wrongly ignored their entitlement to compensation under Section 163-A. They also relied on Supreme Court precedents dealing with no-fault compensation.
Court's Observations
Justice Venkateswarlu Nimmagadda found fault with the Tribunal's approach in rejecting the oral evidence regarding the deceased's employment as a tractor driver merely because no salary records had been produced.
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The Court observed,
"The oral evidence is also valuable evidence unless rebutted."
It noted that in the agricultural sector, wages are often paid informally and documentary proof may not always exist. Therefore, credible oral testimony cannot be discarded solely for lack of written records.
The Court also rejected the insurer's argument that the deceased's alleged negligence barred the claim.
Referring to Section 163-A of the Motor Vehicles Act, the bench observed,
"The question of negligence of the deceased is not a relevant factor while considering a claim under Section 163-A."
It emphasized that the provision is intended to provide speedy relief without requiring proof of fault.
The Court further noted that although the insurer claimed the deceased lacked a valid driving licence, no evidence had been produced to support that allegation. In the absence of such proof, the Court held that the presumption would favour the claimants.
Decision
Allowing the appeal, the High Court held that the Tribunal's award was inconsistent with the legal principles governing compensation under the Motor Vehicles Act.
Taking note of the beneficial nature of the legislation and the compensation framework introduced through the 2019 amendment, the Court awarded ₹5 lakh to the claimants. Of this amount, ₹3.5 lakh was directed to be paid to the widow and ₹1.5 lakh to the son.
The Court also directed payment of 9% annual interest from the date of filing of the claim petition until realization.
The appeal was accordingly allowed, with no order as to costs.
Case Details
Case Title: Veerapaneni Venkata Subhashini & Anr. v. Arikatla Venkata Rathnam & Anr.
Case Number: MACMA No. 262 of 2023
Judge: Justice Venkateswarlu Nimmagadda
Decision Date: 07 May 2026
