The Supreme Court of India has delivered a significant ruling, expanding the interpretation of ‘legal representative’ under the Motor Vehicles Act. The judgment ensures that individuals who were financially dependent on the deceased, even if they are not immediate family members, can claim compensation for their loss.
The bench comprising Justice Sanjay Karol and Justice Prashant Kumar Mishra set aside a High Court ruling that had denied compensation to the father and younger sister of a deceased accident victim, recognizing them as rightful claimants under the Act.
Background of the Case
The case, Sadhana Tomar & Ors. vs. Ashok Kushwaha & Ors., revolved around the tragic death of Dheeraj Singh Tomar, a 24-year-old who lost his life in a motor vehicle accident. He was a wholesale fruit seller, contributing financially to his family’s livelihood. His dependents, including his father and younger sister, filed a claim for compensation.
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The Motor Accident Claims Tribunal (MACT), however, awarded compensation only to certain claimants while excluding the father and sister, reasoning that they were not considered dependents under the Act. The High Court upheld this decision, prompting an appeal to the Supreme Court.
The Supreme Court ruled in favor of the appellants, stating that the term ‘legal representative’ should be interpreted broadly. The Court emphasized:
“The term ‘legal representative’ should not be confined only to mean the spouse, parents, and children of the deceased. The Motor Vehicles Act is a benevolent legislation meant to provide financial relief to families affected by road accidents.”
The Court referred to several key judgments, including:
Gujarat SRTC v. Ramanbhai Prabhatbhai (1987) 3 SCC 234 – Held that a legal representative includes any individual who suffers financial loss due to the deceased’s death, not necessarily just immediate family.
N. Jayasree v. Cholamandalam MS General Insurance Company Ltd. (2022) 14 SCC 712 – Stressed that claimants only need to establish a loss of dependency to claim compensation under the Motor Vehicles Act.
National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680 – Established guidelines on determining compensation based on income, future prospects, and applicable multipliers.
The Supreme Court overruled the High Court’s decision and re-evaluated the compensation, considering the deceased’s income and dependents.
Revised Compensation Calculation:
- Monthly Income: ₹6,500 (as per minimum wage standards)
- Annual Income: ₹78,000
- Future Prospects (40%): ₹1,09,200
- Deduction for Personal Expenses (1/4th): ₹27,300
- Multiplier (18) Applied: ₹14,74,200
- Loss of Estate & Funeral Expenses: ₹18,150 each
- Loss of Consortium (₹48,400 per dependent for 5 dependents): ₹2,42,000
- Total Compensation Awarded: ₹17,52,500
The Supreme Court also upheld the High Court’s order directing the insurance company to first pay the compensation and then recover it from the vehicle owner and driver, who were found jointly and severally liable for the accident.
This ruling ensures broader financial protection for families affected by motor accidents. The judgment clarifies that financial dependency, rather than strict family relationships, determines eligibility for compensation. The Supreme Court’s decision sets a strong precedent for future claims, emphasizing that the Motor Vehicles Act should be interpreted to serve justice rather than limit rightful claimants.
This judgment reinforces the principle that compensation should reach all those who suffer due to a tragic accident, ensuring that justice is not denied due to restrictive legal interpretations.
Case Title: SADHANA TOMAR & ORS. VERSUS ASHOK KUSHWAHA & ORS.
