04.09.2025 TWO SUPREME COURT IMPORTANT JUDGMENTS ON ACCIDENT COMPENSATION

Описание: Death 5 Months After Accident: Supreme Court Denies Claim, Cites No Direct Link to Accident!
1. Motor Vehicles Act, 1988 - Principle of Causation - To claim compensation for death, a direct and proximate nexus between the injuries sustained in the motor accident and the subsequent death must be established through clear evidence. Merely the proximity in time between the accident and death is insufficient to prove causation, especially when there are intervening medical events and pre-existing health conditions. (Based on Paragraphs 8, 9, 11)
2. Law of Evidence - Onus of Proof in Accident Claims - The onus is on the claimants to prove, even on a preponderance of probability, that the death was a direct result of the accident. This burden is not discharged when expert medical opinion points towards other possible causes of death, such as post-operative complications arising from the patient's pre-existing adverse medical parameters (like diabetes and high cholesterol), and where a post-mortem was not conducted to ascertain the definitive cause of death. (Based on Paragraphs 6, 8, 11)
3. Motor Vehicles Act, 1988 - Compensation for Death - A claim for compensation for death cannot be sustained where the death occurred almost five months after the accident due to pulmonary embolism/acute myocardial infarction following a surgery. If evidence shows the initial injuries were not very serious and the death could very well have been an after-effect of the surgery given the patient's medical history, the causal link to the accident is broken. (Based on Paragraphs 8, 10, 11)
Case Title Haseena Versus The United India Insurance Co. Ltd.
Case Number Civil Appeal No. 6621 of 2025
Date of Decision 04.09.2025
Judges Hon’ble Mr. Justice K. Vinod Chandran and Hon’ble Mr. Justice N.V. Anjaria

SC Enhances Biker's Compensation to ₹48 Lakhs After Leg Amputation, Accepts ITR as Income Proof!
1. Motor Vehicles Act, 1988 – Assessment of Compensation – Functional Disability vs. Medical Disability For awarding compensation in motor accident claims, the key consideration is the 'functional disability' that impacts the claimant's earning capacity, which may differ from the 'medical disability' stated in a certificate. Even where a medical certificate indicates 90% disability due to amputation, if the claimant, with the aid of a prosthetic limb, can continue their business, assessing the functional disability at a lower percentage (e.g., 50%) for computing the loss of earning capacity is justified and reasonable. (Para 7)
2. Motor Vehicles Act, 1988 – Assessment of Compensation – Determination of Income Income Tax Returns (ITRs) filed by a claimant for assessment years preceding the accident are credible evidence of income and should not be disbelieved as fabricated or as a mere tax-saving device. Courts must accept such ITRs to determine the claimant's income for calculating compensation, after deducting the applicable tax. Rejecting ITRs on the basis of mere surmises and conjectures is impermissible. (Para 8)
3. Motor Vehicles Act, 1988 – Assessment of Compensation – Future Prospects in Injury Cases An addition for future prospects is not an automatic entitlement in disability cases. Where a claimant's loss of earning capacity due to functional disability has been reasonably compensated and they are in a position to continue their business (e.g., with a prosthetic limb), a separate award for future prospects on top of the calculated income loss is improper. (Para 9)
4. Principle of Law – Just Compensation – Medical & Future Expenses A claimant is entitled to reimbursement of the full amount of medical expenses for which bills and invoices are produced on record; this amount cannot be arbitrarily reduced without proper reasoning. In cases involving amputation and the need for a prosthetic limb, courts must award a substantial and reasonable lumpsum amount for future medical expenses to cover the periodical servicing, maintenance, and replacement of the prosthesis and its accessories. (Para 10, 12)
Case Title Anoop Maheshwari vs. Oriental Insurance Company Ltd.
Case Number Civil Appeal Nos. 12098-12099 of 2024
Bench Hon’ble Mr. Justice K. Vinod Chandran, Hon’ble Mr. Justice N.V. Anjaria