Meena Jain vs United India Insurance Co. Ltd 2025 INSC 1125 - Motor Accident Compensation
Motor Vehicles Act, 1988 - Section 166 - While upholding dismissal of Motor Accident Compensation claim, SC observed: A claim for compensation for death or injury can be pursued only if there is established negligence on the part of the driver of the offending vehicle. Obviously, even if the driver of the subject vehicle is found to be negligent, there can be no compensation for his death, since he is the tort-feasor. The compensation with respect to the child could have been considered which also fails due to absence of any pleading of negligence. (Para 4) The unfortunate accident occurred on 05.09.1993 and on that date Section 163A of the MV Act was not available in the statute, disentitling even the no fault liability claim under the MV Act. The provision under Section 163A was brought into the MV Act only with effect from 19.11.1994. (Para %)
Case Info
Case Name and Neutral Citation
- Case Name: Meena Jain & Anr. v. United India Insurance Co. Ltd. & Ors.
- Neutral Citation: 2025 INSC 1125
Coram (Judges)
- Justice K. Vinod Chandran
- Justice N.V. Anjaria
Judgment Date
- Date: August 22, 2025
Caselaws and Citations
- National Insurance Company Ltd v. Balakrishnan and Anr.Citation: (2013) 1 SCC 731
Statutes/Laws Referred
- Section 166 of the Indian Motor Vehicles Act, 1988 (MV Act)
- Section 163A of the Indian Motor Vehicles Act, 1988 (noted as not applicable to the accident date)
Q&A
Q: Who were the appellants and respondents in this Supreme Court case?A: The appellants were Meena Jain & Anr., and the respondents were United India Insurance Co. Ltd. & Ors.
Q: What was the incident that led to the claim petitions?A: The claimants were involved in a car accident where the car collided with a Neem tree, resulting in the death of the driver (the breadwinner) and his minor child.
Q: Why did the Motor Accident Claims Tribunal dismiss the claim petitions?A: The Tribunal dismissed the claims because there was no negligence proved, and the oral evidence about a truck causing the accident was not supported by the pleadings.
Q: What is required under Section 166 of the Indian Motor Vehicles Act, 1988 to claim compensation?A: There must be established negligence on the part of the driver of the offending vehicle.
Q: Why was compensation for the death of the driver not allowed?A: Because the driver was considered the tort-feasor (the person responsible for the accident), compensation cannot be awarded for his own death.
Q: Was Section 163A of the Motor Vehicles Act applicable to this case? A: No, Section 163A was not available on the date of the accident (05.09.1993); it was added to the Act only from 19.11.1994.
Q: What precedent did the appellants rely on, and why did it not help their case?A: They relied on National Insurance Company Ltd v. Balakrishnan and Anr. [(2013) 1 SCC 731], but the Supreme Court held that the precedent did not apply to their situation.
Q: What was the final decision of the Supreme Court in this case?A: The Supreme Court dismissed the appeals and upheld the judgment of the High Court. Pending applications, if any, were also disposed of.