M/s. Purohit and Company v. Khatoonbee and Anr.
Background
The respondents' daughter died in a motor accident on 02.02.1977, but they filed a compensation claim under Section 166 of the Motor Vehicles Act, 1988 only on 23.02.2005: more than 28 years later. The appellant (the vehicle owner/company) sought rejection of the claim as time-barred, but the Motor Accident Claims Tribunal entertained it, and the High Court upheld this, reasoning that no limitation period is prescribed under the 1988 Act for such claims. The appellant challenged this before the Supreme Court.
Decision Breakdown
The Supreme Court held that even though Section 166 of the Motor Vehicles Act (after a 1994 amendment) prescribes no fixed limitation period, a claim must still be raised within a "reasonable time," drawing an analogy from its own precedents under the Industrial Disputes Act and Consumer Protection Act where claims filed after years of delay without limitation periods were still held to be "not surviving" or "stale" claims. The Court found that a 28-year delay could not, on any reasonable view, be treated as acceptable, and rejected the claimants' stated justification (poverty and lack of legal knowledge) as insufficient to excuse such an extraordinary lapse of time. It accordingly set aside the High Court's order and held that the claim was a "dead claim" by the time it was filed, allowing the appeal, while directing that Rs. 25,000 already deposited by the appellant for litigation costs be transmitted to the respondents.
Lesson Learnt
The absence of a statutory limitation period does not mean a claim can be filed at any time: courts will still require that a claim be brought within a "reasonable time," and an extraordinarily long, unexplained delay (such as 28 years here) can render even an otherwise valid claim legally dead.