Supreme Court Rules No Compensation Under Motor Vehicles Act Without Causal Link to Vehicle Use
The Supreme Court of India held that compensation under the Motor Vehicles Act, 1988 cannot be awarded unless a direct or consequential causal relationship is established between the death of a victim and the actual use of the motor vehicle.
A Division Bench comprising Justice Sanjay Karol and Justice Augustine George Masih delivered the verdict in an appeal filed by Dilip Agarwal against Rajshri Agarwal and others. The case originated from the death of a man named Anand, who sat in a vehicle driven by his friend, Dilip Agarwal, in November 2009 and was found dead three days later. While Dilip was acquitted of murder charges in criminal proceedings, the victim’s family filed a claim before the Motor Accident Claims Tribunal under Section 166 of the Act, alleging the vehicle was used during the crime.
Both the Tribunal and the High Court awarded compensation to the family, concluding that the injuries were inflicted inside the vehicle and led to his death.
Reversing the lower court decisions, the Supreme Court emphasized that while civil claims are decided on the standard of preponderance of probabilities rather than proof beyond reasonable doubt, a basic causal link between the vehicle and the incident must still be proved. The apex court observed that no forensic evidence, such as blood or hair, was found inside the car, nor was the vehicle involved in any collision.
The Court clarified that mere involvement of a vehicle somewhere in a chain of events does not trigger liability under motor accident law. Setting aside the compensation awards, the Bench allowed the appeal, though it directed that any amount already paid to the claimants shall not be recovered.