No compensation under Motor Vehicles Act for deaths caused by rash driving, says Supreme Court: Report

Motor Vehicle Act

In a key ruling on July 2, the Supreme Court held that legal heirs of individuals who die due to their own negligent driving are not entitled to compensation under the Motor Vehicles Act.

According to a report by Livelaw, a news platform that provides updates on real-time court hearings, the judgment reinforces the legal position that if a person causes their own death through reckless driving, their dependents cannot claim damages from insurance companies.

The report said, the case arose from the death of a man who was driving a Fiat Linea on June 18, 2014, when the vehicle overturned. He was accompanied by his family, including his father, sister, and niece. His family claimed a tyre burst led to the crash, but the police investigation and chargesheet confirmed that the accident was caused by his “rash and negligent driving.”

According to the Livelaw report, his wife, son, and parents filed a compensation claim of Rs 80 lakh, citing his monthly income of Rs 3 lakh and his status as the family’s primary breadwinner. The claim was made against United India Insurance Co Ltd.

The Motor Accident Claims Tribunal rejected the claim, concluding that he was a “self-tortfeasor”, which refers to a person responsible for his own injury or death, and therefore could not be considered a “victim” under the Motor Vehicles Act.

The Motor Accident Claims Tribunal (MACT) is a special court in India set up under the Motor Vehicles Act, 1988 to provide compensation to victims of road accidents or their legal heirs.

The Karnataka High Court upheld this finding, citing precedents including the Supreme Court’s 2009 judgment in ‘Ningamma v. United India Insurance Co Ltd’, which had held that compensation cannot be granted when the accident is caused by the deceased’s own negligence.

What evidence led to the rejection of the compensation claim?

According to experts, the court proceedings found that the accident was due to his own negligence based on multiple pieces of evidence presented during the investigation and trial phases.

Police chargesheet

The police investigation, which is often “primary” to the case, concluded that the accident was caused by his rash and negligent driving. This official finding formed the foundational basis for the tribunal and court decisions.

Eyewitness accounts and case records

The records reviewed by the Motor Accident Claims Tribunal and the Karnataka High Court did not support the family’s claim that a tyre burst caused the crash.

There might have been no credible evidence to prove a mechanical fault, experts said.

Tribunal’s observations

According to the Livelaw report, the Motor Accident Claims Tribunal specifically noted that the manner in which the vehicle was being driven, at a high speed and in a careless fashion, led to the accident. This aligned with the conclusion that he himself was responsible.

No evidence of external fault

Courts noted the absence of any reliable technical or expert report confirming a tyre burst or other external factor.

This made the theory of a mechanical failure speculative and unsupported, experts explained.

Legal principle applied

Based on the evidence, the Tribunal and the High Court applied the legal doctrine of “self-tortfeasor”, which refers to a person who causes their own injury.

“The courts based their conclusion on the police report, the lack of proof for any external or third-party cause, and the legal principle that one cannot claim compensation for harm caused by their own unlawful conduct,” stated experts.

The matter was taken to the Supreme Court, where a Bench comprising Justices PS Narasimha and R Mahadevan reaffirmed the decisions of the lower courts.

The Bench said, if further noted that in situations where the deceased was not the owner of the vehicle but was in control of it at the time of the accident, the legal liability remains with the person driving.

Thus, even if the driver is a borrower and not the registered owner, the insurer has no obligation to compensate in the event of self-caused death.