The Supreme Court of India has ruled that the definition of a ‘legal representative’ in motor accident claims should be interpreted broadly, allowing any suffering dependent to seek compensation, rather than restricting the term solely to immediate family members. The decision was delivered by a bench comprising Justice Sanjay Karol and Justice Prashant Kumar Mishra in Civil Appeal No. 3763 of 2025 (arising out of SLP(C) No. 6986 of 2023), brought by Sadhana Tomar and others against Ashok Kushwaha and others.
Background of the Case
The case arose from a fatal road accident on September 25, 2016, in which Dheeraj Singh Tomar, a 24-year-old fruit seller, lost his life when the auto-rickshaw he was traveling in overturned due to the driver’s negligent and rash driving near Gohad Chauraha Road, Gwalior, Madhya Pradesh. His family, including his mother, siblings, and father, filed a claim for compensation under the Motor Vehicles Act, 1988.
The Motor Accidents Claims Tribunal (MACT), Gwalior, in its order dated October 9, 2018, awarded Rs. 9,77,200 with 7% interest per annum, but did not consider the deceased’s father and younger sister as dependents. The decision was upheld by the Madhya Pradesh High Court (Gwalior Bench) on September 19, 2022, which ruled that the insurance company would pay the compensation and recover it from the vehicle’s owner and driver, who were jointly and severally liable due to the lack of a valid driving license.
Key Legal Issues
Assessment of the deceased’s monthly income:
The MACT and High Court had taken Rs. 4,500 per month as the deceased’s income, applying a 1/3rd deduction for personal expenses and fixing the future prospects at 40%.
The appellants argued that the deceased was earning Rs. 35,000 per month from a wholesale fruit-selling business.
Dependency considerations:
The father and younger sister were not considered dependents by the Tribunal and High Court, reducing the number of claimants and increasing the personal expense deduction.
Applicability of a higher multiplier for compensation calculation:
The appellants contested the multiplier applied by the lower courts, seeking a revised compensation amount.
Supreme Court’s Observations and Decision
The apex court disagreed with the lower courts on the assessment of the deceased’s income and the exclusion of the father and younger sister as dependents. It recalculated the compensation as follows:
Monthly income fixed at Rs. 6,500 as per the Minimum Wages Act, 1948 (2016 Notification).
Annual income: Rs. 78,000 (after considering future prospects at 40%).
Multiplier of 18 (as per National Insurance Co. Ltd. v. Pranay Sethi [(2017) 16 SCC 680]).
Personal expense deduction reduced to 1/4th, considering five claimants.
Final Compensation: Rs. 17,52,500.
The Court, citing N. Jayasree v. Cholamandalam MS General Insurance Co. Ltd. [(2022) 14 SCC 712], emphasized that:
“The term ‘legal representative’ should be given a wider interpretation… The MV Act is a benevolent legislation enacted for the object of providing monetary relief to victims or their families. Any dependent who suffers on account of the death of a person in a motor vehicle accident should have a remedy for realization of compensation.”
Thus, the Court ruled that the father and younger sister should be considered legal representatives, reversing the lower courts’ narrow interpretation of dependency.
The Supreme Court allowed the appeal and directed the insurance company to pay the revised compensation of Rs. 17,52,500, upholding the High Court’s direction that it could recover the amount from the driver and vehicle owner.
In conclusion, the ruling establishes a progressive precedent in motor accident claims, ensuring that any suffering dependent can claim compensation rather than being restricted to immediate family members. This decision strengthens the beneficiary-centric approach of the Motor Vehicles Act, 1988, reaffirming the judiciary’s commitment to justice and equitable relief for accident victims and their dependents.
