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Legal Case Shots

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Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Motor Accident Compensation LawSupreme Court of India

Amarveer Kaur v. Reliance General Insurance Company Ltd.

Civil Appeal · 2025 INSC 589Decided 29 Apr 2025
C.A. No. 5662-5663 of 2025 (arising from SLP(C) Nos. 22192-93 of 2018, with connected SLP(C) Nos. 8172-73 of 2019)
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

After a man died in a motor accident leaving behind his wife, two minor children, and his parents, the Motor Accidents Claims Tribunal awarded the family about Rs. 23.15 lakh, holding the insurance company liable despite its argument that the driver's licence was fake. On appeal, the High Court reduced the award, cutting the assessed monthly income from Rs. 15,000 (as an accountant) to just Rs. 3,700 (as an unskilled worker) after finding the claimants' evidence of the higher salary unreliable, while still fixing the insurer's liability (with a right to recover from the vehicle owner).

Decision Breakdown

The Supreme Court agreed that the deceased's claimed salary as an accountant was rightly rejected for lack of proof, but found the High Court's Rs. 3,700 figure unexplained and unsupported by any document; instead it applied the Court's own established benchmark for unskilled/self-employed workers (from Ramachandrappa v. Royal Sundaram, updated for inflation via annual increments as recognized in the Pranay Sethi precedent), arriving at a fairer notional monthly income of Rs. 7,500. Applying the correct multiplier for the deceased's actual age (per the postmortem report), a 1/4 deduction for personal expenses (given six family dependents), a 40% future-prospects addition, and awarding "loss of consortium" not just to the widow but also to the two children and both parents (following New India Assurance v. Somwati), the Court recalculated the total compensation upward to Rs. 18,36,500. On liability, the Court found no need to decide the disputed driving-licence's validity for the goods vehicle, and upheld the earlier arrangement making the insurer pay the claimants while it recovers the amount from the vehicle's owner.

Lesson Learnt

In fatal accident claims, courts must fix the deceased's notional income using proper wage benchmarks (not arbitrary figures), and compensation for "loss of consortium" is not limited to a spouse: children and parents of the deceased are separately entitled to it as well.

Amarveer Kaur v. Reliance General Insurance Company Ltd. – Legal Case Shots | LegalAware