In a significant ruling reaffirming the importance of substance over form in motor accident claims, the Supreme Court of India has set aside a Karnataka High Court order that had denied compensation due to a discrepancy in the make of the offending vehicle, stating that “mere misdescription of the make of the vehicle could not have been treated as a ground to dismiss the claim petition.”
The judgment was delivered on February 10, 2025, in Civil Appeal arising out of SLP (C) No. 27072 of 2024, titled Parameshwar Subray Hegde vs New India Assurance Co. Ltd. & Anr. The Bench comprised Justice J.K. Maheshwari and Justice Aravind Kumar.
Background of the Case
The appellant, Parameshwar Subray Hegde, was a grievously injured victim in a motor vehicle accident and had filed a claim before the Motor Accidents Claims Tribunal (M.V.C. No. 121 of 2014) in Sirsi. The Tribunal had awarded him compensation of ₹40,000 with interest at 6% per annum via its judgment dated August 20, 2015.
However, the High Court of Karnataka, Circuit Bench at Dharwad, in its judgment dated April 18, 2017 (MFA No. 103716 of 2015), overturned the award. The reason: the vehicle was described in the claim petition as a TATA Spacio, while in reality, it was a TATA Sumo—though the registration number (KA-31/6059) remained consistent.
Legal Issues Involved
Whether a misdescription of the make of a vehicle in a claim petition is sufficient ground to reject compensation.
Whether the High Court was justified in setting aside the Tribunal’s award purely on this basis.
Whether delay in approaching the Supreme Court affects the award of interest.
Supreme Court’s Observations & Ruling
The Supreme Court ruled that the High Court erred in dismissing the claim. The Justices observed:
“Even mere misdescription of the make of the vehicle could not have been treated as consistency or a ground to dismiss the claim petition itself, particularly when there is no change in the registration number of the offending vehicle.”
The Court emphasized that the registration number was consistent and had been part of the criminal case arising from the accident, making the vehicle’s identity clear despite the discrepancy in its make.
The Supreme Court:
Set aside the Karnataka High Court’s judgment.
Restored the Tribunal’s compensation award of ₹40,000 with 6% annual interest.
Held that due to the delay in filing the appeal (a cumulative delay of 1380 days), the claimant would not be entitled to interest for the delayed period.
The judgment concluded with the Court directing the first respondent, New India Assurance Co. Ltd., to pay the compensation excluding interest for the delayed duration.
