Introduction
The Supreme Court considered whether the mere involvement of a motor vehicle in a sequence of events leading to a person’s death is sufficient to impose liability under Sections 165 and 166 of the Motor Vehicles Act, 1988. The issue was whether there must be a direct and proximate connection between the use of the vehicle and the death for compensation to be awarded.
Background
The deceased, who was acquainted with the appellant, travelled in a car driven by the appellant’s friend on 29 November 2009. Three days later, his body was discovered near a village.
Following a complaint lodged by the deceased’s wife, the appellant and two others were prosecuted for kidnapping, murder, and criminal conspiracy. Although the trial court convicted the appellant, the Chhattisgarh High Court later acquitted him in 2015 after finding that the prosecution had failed to establish the “last seen” theory.
Meanwhile, the deceased’s widow and children filed a claim petition under the Motor Vehicles Act, alleging that the deceased had been murdered inside the appellant’s vehicle. The Motor Accident Claims Tribunal awarded compensation of more than ₹5.64 lakh, holding that the death arose out of the use of the motor vehicle. The High Court upheld the finding and enhanced the compensation to ₹8.60 lakh, leading to the present appeal before the Supreme Court.
Court’s Decision
The Supreme Court allowed the appeal and set aside the compensation awarded by the Tribunal and the High Court.
The Court held that liability under the Motor Vehicles Act cannot arise merely because a motor vehicle formed part of the chain of circumstances surrounding a person’s death. There must be a clear and proximate causal relationship between the use of the vehicle and the death.
The Bench observed that the courts below had wrongly assumed that the injuries were sustained while the deceased was inside the vehicle, despite there being no evidence to support such a conclusion. It noted that the medical evidence only established that the injuries were caused by hard and blunt objects and did not connect them to the use of the vehicle.
Relying on Rita Devi v. New India Assurance Co. Ltd. (2000), the Court explained that compensation under the Motor Vehicles Act is payable only when the death or injury has a sufficient causal nexus with the use of the vehicle. In Rita Devi, the murder occurred during the theft of an auto-rickshaw, making the death directly connected to the use of the vehicle.
In contrast, the present case lacked any evidence establishing such a connection. The Court held that although there was an alleged murder and a motor vehicle was part of the surrounding circumstances, the necessary legal nexus between the vehicle and the death had not been proved.
Accordingly, the Supreme Court held that the provisions of the Motor Vehicles Act were not attracted and that neither the vehicle owner nor the insurer could be held liable to pay compensation.
Takeaways
The judgment clarifies that compensation under the Motor Vehicles Act is not available merely because a vehicle is incidentally connected to an incident resulting in death. Claimants must establish a direct and proximate causal relationship between the use of the motor vehicle and the death or injury. Without such a nexus, liability under Sections 165 and 166 of the Motor Vehicles Act cannot be imposed.
Case Title: Dilip Agarwal v. Rajshri Agarwal & Ors.
