Urmila Chand vs. Sonu Chand and Others
Background
After her son Priyank Chand died in a 2009 road accident, his mother (the appellant), his widow, and two minor children were awarded compensation of about Rs. 11.82 lakh by the Motor Vehicle Claims Tribunal in Assam. In 2015, on a joint application signed by the appellant and her daughter-in-law, the Tribunal disbursed the money: Rs. 1 lakh to the appellant and larger amounts to the other claimants. Over six months later, the appellant filed a review petition claiming the split was unfair, but both the Tribunal and the Gauhati High Court rejected it as time-barred and unsupported by evidence of any fraud.
Decision Breakdown
The Supreme Court dismissed the appellant's further appeal. It found she had voluntarily signed the joint application and the order-sheet acknowledging receipt of her share, encashed the cheque without objection, and only raised a grievance much later, after the review period had already lapsed. The Court held she could not "approbate and reprobate" (accept a benefit and later dispute the same transaction) and that there was no evidence of fraud vitiating the original disbursement order. Since both the Tribunal and the High Court had correctly found the review time-barred and the appellant's conduct inconsistent with her claims of unfairness, the Court saw no reason to interfere.
Lesson Learnt
A person who knowingly accepts a settlement or payment and signs off on it cannot later reopen the same transaction merely because they have had a change of mind. Courts expect consistency between one's conduct and one's later legal claims, and review petitions must be filed within the prescribed time limit.