Expressing concern over chronic delays in motor accident compensation cases across the country, the Supreme Court has issued a series of directions aimed at expediting proceedings before Motor Accident Claims Tribunals (MACTs) and High Courts.

A Bench of Justice Sanjay Karol and Justice NK Singh Masih noted that an analysis of over a hundred motor accident compensation cases decided by the Supreme Court revealed that the average pendency before Claims Tribunals was approximately six years, while appeals remained pending in High Courts for around eight years.

"The Motor Vehicles Act, 1988, to state the obvious, is a beneficial legislation aimed at providing just and fair compensation. Both of these salutary values are denuded by long pendency," the Court observed.

The Court said that delays at the Tribunal level are often caused by claim petitions being filed without supporting documents, resulting in repeated adjournments for production of evidence. To address this, it directed that claimants must, wherever applicable, furnish relevant documents along with their claim petitions.

The Bench specified that proof of age, excluding Aadhaar cards, must be filed in all cases since age is a crucial factor in determining compensation. In disability claims, certificates issued by competent doctors recording the percentage of disability and the extent of functional disability must be produced. Where a particular income is claimed, supporting documents such as income tax returns, salary slips, or employer-issued salary certificates under stamp and seal must be annexed. Medical expense claims must be backed by duly attested bills from hospitals or clinics, while claims for attendant charges should be accompanied by a notarised affidavit disclosing the attendant's salary.

Highlighting the alarming pendency in appellate courts, the Supreme Court requested Chief Justices of all High Courts to ensure that long-pending MACT appeals are listed in order of their age. The Court suggested that cases pending for more than four years should receive priority, with the oldest matters being listed first.

"For clarity, it may be stated that if matter 'a' has been pending for eight and a half years and 'b' has been pending for four years, 'a' will be listed first," the Bench said.

The Court also requested Chief Justices to assess whether additional benches dealing with MACT compensation matters are required in their respective High Courts in view of the pendency.

At the Tribunal level, the Court stressed the need for greater use of the summary procedure contemplated under Section 169 of the Motor Vehicles Act. While acknowledging that adoption of a summary procedure is not mandatory, the Bench said Tribunals should record reasons if they choose not to adopt it.

"It would be in the favour of expediency if reasons are recorded by the Tribunals for not choosing to adopt such procedure. If it is adopted where possible it would go a long way in ensuring that the deserved compensation reaches the claimants as soon as possible," the Court observed, directing strict enforcement of the requirement.

The directions were issued in an appeal in which the Court also expressed concern over the prolonged delay faced by compensation claimants and emphasised the need for systemic reforms to ensure timely delivery of relief under the Motor Vehicles Act.

The Court noted that the appeal had been filed before the Punjab and Haryana High Court in 2004 but was decided only at the end of 2024. While acknowledging that the delay was partly attributable to a fire in 2011 that destroyed or damaged thousands of court records, the Bench said the circumstances raised troubling questions about institutional delay.

"It appears from the perusal of records of the High Court that the file of this case amongst thousands of others was either partially burnt or completely destroyed in a fire that occurred in 2011," the Court noted.

Referring to administrative efforts to reconstruct destroyed files, the Bench observed that a February 2024 order of the High Court recorded that nearly 2,200 cases whose records could not be traced had been removed from the list of pending reconstruction matters and placed in a separate category awaiting intervention by counsel.

Questioning the extraordinary delay, the Court remarked:

"The appeal was filed before the High Court in 2004. The unfortunate fire incident happened in 2011. The case came to be decided at the fag-end of 2024. Naturally, two questions arise, one why was the case arising out of a beneficial legislation remained pending in 2011 when it was filed in 2004? Two, still further, between 2011 and 2024 is a period of 14 years – does the reconstruction of a file or number of files, takes 14 years?"

The Court emphasised that such delays reflect on institutions entrusted with adjudicating rights and observed that the suffering of claimants is aggravated when compensation claims remain unresolved for decades.

"Although it is never possible to fully compensate for the loss of a person who has been an integral part of a person's family, the idea of 'just and fair' compensation requires that an amount of money be paid to the claimants that would, as far as possible, place them in a position as if the unfortunate incident of the death of their loved one had not taken place. For whatever reason, when this takes twenty years, the suffering is only compounded further," the Bench observed.

To assess the extent of the problem, the Bench examined more than one hundred MACT appeals decided by Supreme Court Benches headed by Justice Karol. The analysis revealed that the average pendency before Motor Accident Claims Tribunals was approximately six years, while appeals remained pending in High Courts for about eight years.

Calling the situation "an unhappy picture", the Court observed that in nearly half the cases examined, pendency before High Courts exceeded four years. It stressed that courts must remain vigilant in preventing delays and noted that in many cases, the interest accrued during the pendency period becomes a substantial percentage of the compensation itself.

Also from the judgment - 'Homemakers Are Nation Builders' : Supreme Court Quantifies Homemaker Contribution As Rs 30K Per Month In Motor Accident Claims

The Supreme Court has held that the loss of domestic care provided by a homemaker constitutes a distinct and compensable head of damages in motor accident claims, while quantifying the value of such domestic services at a minimum of Rs. 30,000 per month.

The Court ordered :

"We deem it appropriate to direct that when a Motor Accidents Claim Tribunal or the High Court or this Court is concerned with or a case involving the death of a homemaker, in order to overcome the inherent disadvantage accrued against the homemaker on a calculation of compensation on the basis of conservatively computed notional income and while being acutely aware of the dictum in Pranay Sethi (supra) regarding loss of consortium asregarding loss of consortium as also the disposition towards uniformity, that for the three major heads (the homemaker's contribution towards smooth functioning of the household, the loss of maternal support for children and loss of spousal support/the support and care of their child who is an adult, for the parents of the deceased) ..., a composite sum of Rs.30,000/- shall be added under the head of 'loss of domestic care', provided that all three of these heads are met in the given case. This determination shall be revised by 10%, cumulatively, every three years

"It may be clearly stated that this amount of Rs.30,000/- i.e., loss of domestic care is to be taken as a 'stand- in' (basic minimum monthly income) for monthly income in those cases where the homemaker does not have an input into the house, in strictly conventional, monetary terms. In those cases where the homemaker is part of the workforce, the component of loss of domestic care shall be in addition to the monthly income as may be proved before the Tribunal/Courts."

Pronouncing the judgment in an appeal arising out of a motor accident claims, the bench comprising Justice Sanjay Karol and Justice NK Singh observed that the contribution of a homemaker extends beyond the household and plays a vital role in nation-building. The Court emphasized that the loss of domestic care suffered by a family due to the death or incapacitation of a homemaker deserves independent recognition while determining compensation under the Motor Vehicles Act.

"We are also of the view that the housewife contributes to the growth of the human being and the nation. The homemaker builds nation. So we have laid down the principles, and as a nation builder, we have housewife, we have quantified the amount that the loss of domestic care monthly income minimum in any event would be 30,000 per month," Justice Karol said at the time of pronouncement.

Justice Karol said that "loss of domestic care" would be a ground in addition to the heads of damages recognized by the Supreme Court in Pranay Sethi judgment for awarding compensation in motor accident claims.

"We only hope and trust that the word Home Maker will now acquire the acronym of nation builder," Justice Karol said.

On contribution of homemakers

Enhancing compensation payable to the family of a homemaker who died in a road accident in Haryana in November 2001, the Court observed :

"The homemakers, to put it directly, actually are the 'nation builders' and they ought to be recognised as such."

The Court lamented that homemakers continue to be perceived as dependent on earning members despite the household substantially depending on their labour and care. It noted that unpaid domestic and caregiving work performed by women remains economically undervalued despite its enormous contribution to society and the economy.

"It is ironic to describe a homemaker as dependant on earning members, when, in reality the household's functioning depends substantially on the homemaker," the Bench said.

The judgment contains an extensive discussion on the social, emotional, economic and psychological contributions made by homemakers. Referring to women as the first teachers of children and the unseen force behind families, the Court said homemakers play a central role in shaping human capital, social bonds and national development.

The Bench observed that while the contribution of homemakers extends far beyond biological reproduction, they are also largely responsible for preparing the human capital on which the country's economic aspirations rest. It added that the everyday labour of homemakers enables other family members to pursue education, professions and livelihoods.

The Court further noted that women's unpaid caregiving work is estimated to contribute between 15% and 17% of India's GDP, yet remains unpaid and largely unrecognised.

Surveying earlier precedents including Lata Wadhwa v. State of Bihar, Arun Kumar Agrawal v. National Insurance Co. Ltd. and Kirti v. Oriental Insurance Co. Ltd., the Court observed that judicial recognition of the value of homemakers' services has evolved over the years.

In a previous notable judgment delivered in 2024, the Supreme Court (Arvind Kumar Pandey v. Gyanesh Pandey) had observed that the notion that homemakers do not work was wrong, and held that their deemed income must not be less than the minimum wages notified for a daily wager.

The Bench held that compensation calculations must reflect present realities and should not undervalue the contribution of homemakers by relying solely on outdated notional income figures.

While quantifying compensation, the Court fixed the minimum value of loss of domestic care rendered by the deceased homemaker at ₹30,000 per month. The Bench observed during the hearing that the contribution of a homemaker cannot truly be monetised, but courts are required to assign a pecuniary value for the purpose of awarding just compensation.

Directions issued to expedite motor accident claims

The Court also issued directions aimed at ensuring expeditious disposal of motor accident compensation claims. Referring to Section 169 of the Motor Vehicles Act, which envisages a summary procedure before Motor Accident Claims Tribunals, the Bench expressed hope that the provision would be implemented "in letter and spirit."

After examining over a hundred motor accident compensation appeals decided by a Bench presided over by Justice Karol, the Court noted that in nearly half the cases, pendency exceeded four years. It observed that courts must remain vigilant regarding delays in such matters and emphasised that claims arising out of beneficial legislation should ordinarily not remain pending before High Courts for more than four years.

Further, the Court expressed its expectation that the Chief Justices of all High Courts would monitor motor accident claim proceedings to ensure timely adjudication and effective implementation of the principles laid down in the judgment.

Case : SHISHUPAL @ SHISH RAM AND ORS. v. SURJEET AND ORS |  SLP(C) No. 33915/2025

Citation : 2026 LiveLaw (SC) 617

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