Supreme Court Absolves Minor in Accident Case, Directs Insurance Company to Pay Compensation

In a significant ruling, the Supreme Court of India absolved a minor of liability in a fatal road accident while holding the insurance company responsible for compensating the victims’ family. The case involved a motor vehicle accident in Karnataka, where a minor was alleged to have been driving the offending vehicle. The Court ruled that there was no substantial evidence proving the minor’s involvement and directed the insurance company to release compensation without recovery from the vehicle owner.

Background of the Case

The case stemmed from an accident on January 13, 2016, in Vijaya Nagar, Belagavi. The deceased, Vijay Jumnalkar, was hit by a Bolero vehicle (KA-22-P-1449) while standing on the roadside making a phone call. The vehicle allegedly dragged him for some distance, causing fatal injuries. An FIR was registered against the vehicle owner and a minor (Appellant No. 2), who was claimed to be driving at the time.

The Motor Accident Claims Tribunal (MACT) ruled that the accident was caused due to the negligence of the minor driver and awarded Rs. 7,74,088/- as compensation to the deceased’s family. The claimants appealed to the Karnataka High Court, which increased the compensation to Rs. 21,82,800/- and directed the insurance company to pay and recover the amount from the owner. The vehicle owner and the minor then appealed before the Supreme Court.

Legal Issues

Whether the minor (Appellant No. 2) was driving the vehicle at the time of the accident.
Whether the insurance company was liable to pay compensation without the right to recover from the vehicle owner.
The validity of the findings by the MACT and the High Court regarding negligence.

Arguments by the Appellants

The appellants contended that:

The minor was merely a passenger in the vehicle, and his father was the actual driver at the time of the accident.
The accident was due to the negligence of the deceased, who was talking on the phone while standing on the roadside.
The claimants colluded with the police to falsely implicate the minor in criminal charges.
The High Court erred in affirming the minor’s liability and permitting the insurance company to recover compensation from the owner.

“The courts below failed to appreciate the evidence correctly and wrongly held the minor responsible for driving the vehicle.”

Arguments by the Respondents

The respondents (family of the deceased) argued:

The accident occurred solely due to the rash and negligent driving of the minor.
The compensation awarded by the High Court should be enhanced further.
The deceased was the sole breadwinner of his family, and his dependents, including a mentally disabled son, required additional financial support.

“The deceased’s family has suffered irreparable loss, and the compensation awarded should be increased to reflect their financial dependency.”

Supreme Court’s Observations

After examining the evidence, the Supreme Court noted:

The testimony of key witnesses, including the complainant, did not conclusively establish that the minor was driving the vehicle.
An eyewitness stated that an adult (father of the minor) was behind the wheel at the time of the accident.
The FIR and police chargesheet did not contain substantial proof directly implicating the minor.
The insurance company had already assumed liability under the policy, and recovery from the owner was unwarranted.

“There is no credible evidence linking the minor to the accident. Holding him responsible would be a miscarriage of justice.”

Final Judgment

The Supreme Court ruled:

“The findings of the lower courts regarding the involvement of the minor in the accident are set aside. The insurance company shall pay the compensation of Rs. 21,82,800/- with 6% interest per annum to the claimants. The direction allowing recovery from the vehicle owner is quashed.”

This judgment ensures that minors are not wrongly held accountable in motor accident cases and affirms the principle of fair adjudication based on substantial evidence.

Impact of the Judgment

The ruling has far-reaching implications:

It establishes that minors cannot be presumed guilty in motor accident cases without clear evidence.
It protects vehicle owners from arbitrary liability when the insurer has accepted responsibility.
It reinforces the necessity of factual accuracy in accident investigations.
It upholds fair compensation rights for victims’ families without unjust recovery from vehicle owners.

This decision strengthens legal safeguards in accident cases and ensures that justice is based on evidence rather than assumptions.

Petitioner Name: Sachin Yallappa Usulkar & Others.
Respondent Name: Vijayata & Others.
Judgment By: Justice B.V. Nagarathna, Justice Satish Chandra Sharma.
Place Of Incident: Belagavi, Karnataka.
Judgment Date: 28-02-2025.

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