The Supreme Court of India, in its judgment dated July 14, 2025, held that legal heirs are entitled to continue pursuing compensation claims under the Motor Vehicles Act even if the injured claimant dies during the pendency of proceedings. The Court enhanced the total compensation to ₹12,53,770, to be distributed equally among the legal heirs of the deceased claimant, Meena.
Background of the Case:
The case arose from a motor accident on June 4, 2005, in which Meena, aged 50, suffered severe injuries leading to 100% disability. She filed a claim before the Motor Accidents Claims Tribunal (MACT), which assessed her monthly income at ₹3,000, applied a multiplier of 13, and awarded ₹4,60,000 towards loss of income. Additional amounts were granted for pain and suffering (₹50,000), attendant charges (₹1,20,000), medical expenses (₹1,68,970), and special diet and transportation (₹50,000), totaling ₹8,56,970.
The High Court marginally enhanced the compensation by awarding ₹50,000 more for pain and suffering, and ₹1 lakh each for loss of amenities and future medical treatment. During the pendency of the appeal before the Supreme Court, Meena passed away on January 25, 2024, and her husband and two daughters were substituted as appellants.
Arguments of the Parties:
The appellants relied on Oriental Insurance Company Limited v. Kahlon @ Jasmail Singh Kahlon [(2022) 13 SCC 494], emphasizing that compensation under the Motor Vehicles Act has a broad meaning, covering the estate left by the deceased. The Supreme Court in that case had held, “if the legal heirs can pursue claims in case of death, there is no reason to prohibit the legal representatives to pursue claims for loss of a property, akin to estate of the injured, if the injured dies subsequently.” The insurance company did not oppose this position.
Court’s Analysis:
The Bench, comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran, accepted the legal position that the right to compensation survives to the estate of the deceased. The Court observed that although Meena’s work in stitching and embroidery was asserted, it was not proved with evidence, and thus the monthly income assessed at ₹3,000 by the Tribunal stood.
The Court further considered that Meena survived almost 19 years in a vegetative state after the accident, incurring additional medical expenses, though not all directly attributable to the accident. Therefore, the Court granted an additional ₹1 lakh for future treatment costs.
Final Compensation Awarded:
| Sr. No. | Heads | Amount |
| 1. | Medical bills | ₹1,68,970 |
| 2. | Special diet & transport | ₹50,000 |
| 3. | Pain and suffering | ₹1,00,000 |
| 4. | Loss of amenities | ₹1,00,000 |
| 5. | Future treatment | ₹2,00,000 |
| 6. | Attendant charges | ₹1,20,000 |
| 7. | Loss of income (₹3000 x 110% x 12 x13) | ₹5,14,800 |
| Total | ₹12,53,770 |
Decision:
The Supreme Court directed that the remaining compensation, after deducting any amounts already disbursed, be paid equally to Meena’s legal heirs within two months. The insurance company was directed to deposit the amounts online into the separate accounts provided by the legal heirs, along with interest as directed by the Tribunal.
The appeal was allowed with these modifications, and all pending applications were disposed of.
Case Details:
- Case Title: Meena (Dead) Represented through LRs vs Prayagraj & Others
- Case No.: Civil Appeal No. … of 2025 (@ SLP (C) No. 12187 of 2019)
- Bench: Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
