Motor Accident Compensation: Supreme Court Reinstates Tribunal’s Award for Victim’s Family

The case of Smt. Suvarnamma & Anr. vs. United India Insurance Company Ltd. & Anr. pertains to a motor accident claim in which the Supreme Court had to decide whether the Karnataka High Court erred in absolving the insurance company from liability. The claimants, the wife and son of the deceased, sought compensation for his death due to a tractor accident.

The Motor Accident Claims Tribunal (MACT) awarded compensation of Rs. 4,31,000 to the legal heirs of the deceased and Rs. 10,000 to his father. However, the High Court overturned the decision, declaring the claim to be based on false grounds. The Supreme Court reinstated the compensation, finding no reason to discard the evidence presented before the Tribunal.

Background of the Case

The deceased, Narasa Reddy, left his home on July 12, 2004, to deliver milk but did not return. The next morning, his wife was informed that he had been run over by a ground-leveling tractor on Chakavelu-Buddalavara Palli Road, resulting in his instantaneous death. The police registered an FIR under Sections 279 and 304(A) of the Indian Penal Code.

The claimants approached the MACT, which found that the accident resulted from the driver’s negligent operation of the tractor. The Tribunal directed both the insurance company and the owner of the tractor to pay compensation jointly and severally. However, the insurance company challenged this decision in the High Court, which ruled in its favor.

Arguments by the Parties

Petitioner’s Arguments (Smt. Suvarnamma & Anr.)

The claimants contended that:

• The Tribunal’s findings were based on valid material and should not have been overturned by the High Court.
• Eyewitness testimony from Eashwara Reddy (PW3) confirmed that the accident occurred due to the driver’s negligence.
• The High Court’s assumption that the deceased was unlawfully traveling on the tractor’s blade was baseless and unsupported by evidence.

Respondents’ Arguments (United India Insurance Co. Ltd.)

The insurance company argued that:

• The claimants misrepresented facts by stating that the deceased was a pedestrian at the time of the accident.
• The High Court correctly dismissed the claim as fraudulent.
• The Tribunal had erred in imposing liability on the insurance company without sufficient proof of negligence.

Supreme Court’s Analysis

The Supreme Court examined the evidence, particularly the testimony of PW3 and the findings of the Tribunal.

• The FIR and eyewitness testimony consistently supported that the deceased was walking on the footpath when the accident occurred.
• The insurance company failed to provide any credible evidence to counter the Tribunal’s findings.
• The driver-owner of the tractor was not examined, which weakened the insurance company’s claim.
• The High Court relied on mere assumptions without any factual basis.

Key Observations by the Court

The Supreme Court ruled:

“Considering the circumstances stated above, in our opinion, the conclusion reached by the Tribunal is a possible view, which could not have been reversed by the High Court by merely making sweeping observations in a casual manner without there being any reliable evidence.”

Final Judgment

The Supreme Court reinstated the Tribunal’s decision and directed the insurance company to pay compensation as originally awarded. It ruled:

“The respondents are jointly and severally liable to pay the total amount of compensation i.e. Rs. 4,31,000 to the appellants herein along with interest @ 6% p.a. from the date of filing of claim petition till the date of realization.”

Conclusion

This judgment affirms the importance of relying on factual evidence in motor accident claims. It ensures that compensation awarded by a Tribunal should not be set aside without substantial grounds. The ruling underscores that insurance companies cannot evade liability based on mere conjectures without disproving the claim with concrete evidence.

Petitioner Name: Smt. Suvarnamma & Anr..
Respondent Name: United India Insurance Company Ltd. & Anr..
Judgment By: Justice N.V. Ramana, Justice S. Abdul Nazeer.
Place Of Incident: Karnataka.
Judgment Date: 11-04-2018.

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