Supreme Court Half Yearly Digest 2025: Motor Accident Claims

Assessment of contributory negligence in a motor accident claim - Contributory negligence cannot be presumed on mere allegations of high-speed driving without direct or corroborative evidence. Contributory negligence must be established through direct or corroborative evidence. Tribunal's assessment of negligence, based on evidence and spot inspection, should be upheld unless demonstrably erroneous. (Para 10 & 11) Prabhavathi v. Bangalore Metropolitan Transport Corporation, 2025 LiveLaw (SC) 266 : 2025 INSC 293Assessment of Income - Income assessment in compensation cases should consider proven income as per payslips and bank statements, and not be arbitrarily reduced. The High Court had reduced the deceased's monthly income from Rs. 62,725/- (as determined by the Tribunal) to Rs. 50,000/-. The Supreme Court restored the Tribunal's assessment, holding that the deceased's last drawn salary of Rs. 62,725/- (as per pay slip) was the correct basis for calculating compensation. (Para 14) Prabhavathi v. Bangalore Metropolitan Transport Corporation, 2025 LiveLaw (SC) 266 : 2025 INSC 293Central Motor Vehicles Rules, 1989, Rule 9 - Whether the absence of the endorsement in the driver's license to drive a vehicle carrying a hazardous vehicle absolved the insurer from honouring the claim because of a breach of condition? Held, Insurer can 'pay and recover' if driver of vehicle meant to carry hazardous substance did not have endorsement under Rule 9. An endorsement under Rule 9 is mandatory in the driving license for driving a vehicle carrying any dangerous or hazardous goods. Rule 9 mandates specialized training (including defensive driving, emergency handling, and product safety) and an endorsement for drivers of vehicles carrying hazardous goods. This training is integral to safe operation, rejecting arguments that the endorsement is a mere formality. The absence of such training directly relates to driving competence, especially for vehicles designed for hazardous cargo. (Para 12, 15 & 17) Chatha Service Station v. Lalmati Devi, 2025 LiveLaw (SC) 408 : 2025 INSC 468 : AIR 2025 SC 2324Compensation - Directions for Direct Bank Transfer of Compensation to Road Accident Victims and Workmen - The Supreme Court, in a suo motu case initiated based on a letter from a retired District Judge, issued comprehensive directions to ensure direct bank transfer of compensation to claimants under the Motor Vehicles Act, 1988, and the Workmen's Compensation Act, 1923. Noting that over Rs 282 crores and Rs 6.61 crores remain unclaimed in Motor Accident Claims Tribunals (MACTs) and Labour Courts in Gujarat, respectively, with similar issues in other states, the Court emphasized the need to address the serious concern of unclaimed compensation. The directions include mandatory submission of claimants' bank account details, Aadhar, PAN, and email IDs; verification of bank accounts by MACTs; and direct transfer of compensation to claimants' accounts. The Court also mandated High Courts to issue practice directions, create dashboards for tracking deposited amounts, and initiate drives with Legal Services Authorities to trace claimants. These directions apply until states frame relevant rules, with compliance reports due by July 30, 2025. (Para 9) In Re Compensation Amounts Deposited with MACT and Labour Courts, 2025 LiveLaw (SC) 455 : 2025 INSC 530Contributory Negligence – Learner's License - In a motor accident claim, contributory negligence cannot be presumed merely from the driver's possession of a learner's license. The collision at the trailer's tail-end did not inherently indicate negligence by the driver. Negligence must be proved by evidence, with preponderance of probabilities as the standard. (Para 12 & 13) Srikrishna Kanta Singh v. Oriental Insurance Company Ltd., 2025 LiveLaw (SC) 352 : 2025 INSC 394Conventional Heads - The appeals arose from a motor vehicle accident resulting in the death of the appellant's parents and younger brother. The appellant, the legal heir of the deceased, sought enhancement of compensation awarded by the Motor Vehicles Accident Tribunal, while the insurer (respondent) sought reduction of the compensation. The Tribunal had awarded Rs. 14,78,000/- for the father's death, Rs. 13,33,936/- for the mother's death, and Rs. 2,45,000/- for the brother's death. The High Court enhanced the compensation to Rs. 30,58,000/-, Rs. 16,34,000/-, and Rs. 5,00,000/- respectively. Whether the High Court erred in awarding compensation exceeding the limits set under conventional heads. The Court upheld the High Court's award under conventional heads, noting that the judgment was delivered prior to the Pranay Sethi decision, which capped such awards at Rs. 70,000/-. However, the Court declined to reduce the compensation, as the difference was not excessive and the appellant had suffered significant loss. The Supreme Court dismissed all appeals, upholding the High Court's enhanced compensation, finding it just and reasonable ...

Supreme Court Half Yearly Digest 2025: Motor Accident Claims

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