The Supreme Court has ruled that a dependent mother cannot be denied compensation in a motor accident claim merely because the deceased government employee’s widow and child received financial assistance under Haryana’s compassionate assistance rules.
A three-judge bench held that while financial assistance paid by the State can be adjusted against compensation under the Motor Vehicles Act to avoid “double benefit,” such deduction cannot wipe out the mother’s independent entitlement as a dependent claimant.
Background of the Case
The case arose from a 2012 road accident in Haryana in which Sachin Kumar, a 25-year-old Haryana Police constable, died after a truck allegedly came onto the wrong side of the road and hit his motorcycle near Rohtak.
His widow, minor daughter, mother, and father approached the Motor Accident Claims Tribunal seeking compensation. The Tribunal awarded over ₹37 lakh with interest, holding that the accident occurred due to rash and negligent driving of the offending vehicle.
Later, the Punjab and Haryana High Court reduced the compensation drastically to ₹7.70 lakh after deducting ₹29.21 lakh received by the family under the Haryana Compassionate Assistance to Dependents of Deceased Government Employees Rules, 2006.
Court’s Observation
The Supreme Court examined whether financial assistance under the 2006 Rules should be deducted from compensation payable under the Motor Vehicles Act. The bench referred to the earlier judgment in Reliance General Insurance Co. Ltd. v. Shashi Sharma, which held that overlapping benefits under the same head of “loss of income” cannot be granted twice.
However, the Court found that the High Court overlooked an important aspect - the deceased’s mother was not eligible to receive financial assistance under the 2006 Rules because the deceased had left behind a widow and child.
The bench observed that denying the mother compensation under the Motor Vehicles Act would unfairly deprive her of relief altogether.
“The mother is not entitled to any ex-gratia financial assistance under the 2006 Rules… however, that does not diminish the independent legal injury suffered by the mother due to the sudden death of her son,” the Court said.
The judges further noted that compensation under welfare legislation must remain “just and adequate” and should not result in “illegal enrichment” of the insurance company.
Decision
The Supreme Court upheld the principle that financial assistance received under the Haryana Rules could be deducted to prevent duplication of compensation for loss of income. At the same time, it restored the deceased mother’s separate share in compensation.
The Court awarded ₹11.30 lakh to the mother, representing one-third of the loss of dependency compensation, in addition to the ₹7.70 lakh already granted by the High Court.
As a result, the total compensation payable to the claimants was enhanced to ₹19.01 lakh along with interest. The respondents were directed to pay the amount within eight weeks.
Case Details
Case Title: Sarla Devi & Ors. v. Reliance General Insurance Company Limited & Ors.
Case Number: Civil Appeal arising out of SLP (Civil) No. 13979 of 2018
Judges: Justice Vikram Nath, Justice Sandeep Mehta, and Justice Vijay Bishnoi
Decision Date: May 26, 2026
