Background:

The present case arose from a fatal motor vehicle accident involving N.S. Ravisha, who was driving a Fiat Linea car. The accident was caused due to Ravisha’s own rash and negligent driving, resulting in his death. His legal heirs- wife, son, and parents, filed a claim for compensation of ₹80 lakhs under Section 166 of the Motor Vehicles Act, 1988, against the insurance company, asserting entitlement as legal representatives of the deceased. The Motor Accident Claims Tribunal (MACT) and the Karnataka High Court both dismissed the claim. The petitioners then approached the Supreme Court through a Special Leave Petition.

Issues

• Whether the legal heirs of a deceased person, who died due to his own negligent driving, are entitled to claim compensation under Section 166 of the Motor Vehicles Act, 1988?

Observations:

The following observations were made by the court:

• • The court observed that the deceased, N.S. Ravisha, was the sole cause of the accident due to his own rash and negligent driving. Therefore, he could not be treated as a “victim” under Section 166 of the Motor Vehicles Act.
• • Legal heirs of a person whose own negligence caused the accident are not entitled to claim compensation under the Act, since the law is intended to compensate innocent third parties.
• • The court relied on earlier rulings, including Minu B. Mehta v. Balkrishna and Ningamma v. United India Insurance Co. Ltd., which clarified that compensation is not payable where the deceased was the tortfeasor.
• • Since the accident was caused solely by the policyholder's own negligence, the insurance company was held not liable to pay compensation to the claimants.
• • The courts consistently held that a claim under Section 166 is not maintainable in such cases, reaffirming that the provision is meant for genuine victims, not wrongdoers or their heirs.

Decision:

The Supreme court in his Judgement:

• • Upheld the decisions of the MACT and the Karnataka High Court, dismissing the Special Leave Petition filed by the legal heirs.
• • The Court reiterated the established legal principle that legal heirs of a deceased person who was driving a vehicle negligently cannot seek compensation under the Motor Vehicles Act for an accident caused by his own rash and negligent driving.
• • The Court reaffirmed the principle that compensation under the Act is available only to innocent victims or their heirs, and not to the heirs of the tortfeasor (the negligent driver).
• • Thus, the appeal was rejected, and the claim for ₹80 lakhs compensation by the deceased’s heirs was denied.

Why this case matters:

• • Confirms that compensation under Section 166 is only for innocent victims or their heirs, not for heirs of negligent drivers.
• • Prevents misuse of compensation claims by heirs of drivers responsible for the accident.
• • Provides legal clarity and consistency on who can claim compensation in motor accident cases.
• • Reinforces accountability for negligent driving.

Laws related thereto:

Under Motor Vehicles Act, 1988:

• Section 166: Provides the right to claim compensation for injury or death arising out of a motor vehicle accident. It allows victims or their legal representatives to seek compensation from the insurer or owner of the vehicle.

• Section 163-A: Deals with no-fault liability for death or permanent disability due to motor accidents, providing compensation regardless of fault, but generally for innocent victims.

Judicial Precedents:

• Minu B. Mehta v. Balkrishna (1977):

Established that the heirs of a negligent driver cannot claim compensation under Section 166, as the Act is meant to protect innocent victims.

• Ningamma v. United India Insurance Co. Ltd. (2009):

Held that compensation is not payable to the heirs of the deceased who was the tortfeasor responsible for the accident.

• Ramesh and Ors. v. New India Assurance Co. Ltd. (2018):

Affirmed that an insurer is not liable to pay compensation if the insured himself was negligent and caused the accident.