Sarla Devi v. Reliance General Insurance Co. Ltd. , 2026 INSC 575 Motor Accident Compensation - Haryana Compassionate Assistance Rules - Mother's Dependency

Motor Accident Compensation - Motor Vehicles Act, 1988 – Section 166 ; Haryana Compassionate Assistance to the Dependents of Deceased Government Employees Rules, 2006 — Under social welfare legislations, the paramount consideration is awarding just and adequate compensation for all dependents of the deceased. We risk diluting the said object if one of the dependents is deprived of the quantum of loss of dependency while the other dependents receive the same in bounty.  Negating the mother’s claim, who is entitled to a 1/3rd share of the total compensation awarded under the head of loss of dependency but is not entitled to any ex gratia financial assistance under the 2006 Rules, and setting off her share also against such financial assistance, would amount to illegal enrichment of the insurance company at the cost of a dependent parent and would defeat and negate her entitlement under the Motor Vehicles Act. (Para 24) [Context: High Court had deducted entire financial assistance from total MV Act compensation, effectively wiping out mother’s share]

Motor Accident Compensation - Motor Vehicles Act, 1988 – Section 166 ; Haryana Compassionate Assistance to the Dependents of Deceased Government Employees Rules, 2006 — The amount receivable by the dependents under the 2006 Rules towards pay and other service-related emoluments is liable to be excluded or deducted while computing compensation under the head of loss of dependency under the Act.  (Para 15)