Introduction
The Supreme Court of India has ruled that the term "legal representative" under the Motor Vehicles Act, 1988, should be interpreted broadly to include all dependents of the deceased, not just immediate family members like spouses, parents, or children. This ruling overturned a decision where the Motor Accident Claims Tribunal (MACT) and the High Court had denied compensation to the deceased's father and younger sister, stating they were not dependents.
Background of the Case
Facts of the Matter
The case arose from a fatal accident on September 25, 2016. The deceased, a 24-year-old wholesale fruit seller, died when the auto-rickshaw he was traveling in overturned due to the driver's rash and negligent driving. The deceased’s family filed a claim petition before the MACT, seeking compensation of ₹28,50,000, asserting that he earned ₹35,000 per month and supported his family.
However, the MACT ruled that:
The deceased's father was not financially dependent on him.
Since the father was alive, the younger sister could not be considered a dependent.
Compensation of ₹9,77,200 was awarded to the mother and elder siblings, while the father and younger sister were denied compensation.
The High Court upheld this decision, prompting the father and younger sister to appeal before the Supreme Court.
Supreme Court's Observations
Broad Interpretation of the Motor Vehicles Act in Compensation Claims
The Supreme Court analyzed the definition of "legal representative" under the Motor Vehicles Act, 1988, and held that it should be interpreted widely to include all dependents, not just immediate family members. The Court rejected the narrow interpretation adopted by the MACT and the High Court.
Key Precedents Considered
Gujarat SRTC v. Ramanbhai Prabhatbhai [(1987) 3 SCC 234]
Held that a legal representative is anyone who suffers due to the deceased’s death, not just spouses, parents, or children.
N. Jayasree v. Cholamandalam MS General Insurance Co. Ltd. [(2022) 14 SCC 712]
Stated that "legal representative" should be interpreted broadly under the MV Act to provide monetary relief to victims’ families.
Meena Devi v. Nunu Chand Mahto [(2023) 1 SCC 204]
Reaffirmed that the MV Act ensures just and fair compensation to dependents through a beneficial interpretation.
National Insurance Co. Ltd. v. Pranay Sethi [(2017) 16 SCC 680]
Clarified the multiplier method for determining compensation based on the deceased's age, which was applied in this case.
Supreme Court's Ruling
The Court emphasized that the Motor Vehicles Act is a welfare legislation meant to provide financial relief to victims' families. It held that:
The deceased’s father and younger sister, being financially dependent, qualify as legal representatives.
The compensation should be revised from ₹9,77,200 to ₹17,52,500, considering future prospects, proper deductions, and the deceased’s age (24 years).
The insurance company must first pay the compensation and then recover it from the driver and vehicle owner, as the driver did not have a valid license.
Conclusion
This landmark ruling underscores the Supreme Court's commitment to ensuring fair compensation for all dependents under the Motor Vehicles Act. By adopting a broader interpretation of "legal representative," the judgment affirms that financial dependency, rather than immediate family status, should determine eligibility for compensation.
Case Details
Case Name: Sadhana Tomar & Ors. vs. Ashok Kushwaha & Ors.
Civil Appeal No.: 3763 of 2025
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