Summary of Judgment Of Meena (Dead) Thr. LRs. vs. Prayagraj & Ors.

Related Law:
Motor Vehicles Act, 1988 (Compensation for motor accident claims)

Citation: 2025 INSC 820
Case Title: Meena (Dead) Thr. LRs. vs. Prayagraj & Ors.
Civil Appeal No.: 9458 of 2025 (@ SLP (C) No. 12187 of 2019)
Court: Supreme Court of India
Judges: Hon’ble Mr. Justice Sudhanshu Dhulia & Hon’ble Mr. Justice K. Vinod Chandran
Date of Judgment: 14th July 2025

Background

1. Original Claim: The case arose from a motor accident on 04.06.2005, where Meena (the claimant) suffered 100% disability while traveling in a bus.

2. Tribunal’s Award (2005):
   Loss of income: ₹4,60,000 (based on ₹3,000/month income, multiplier of 13).
   Additional compensation: ₹50,000 (pain/suffering), ₹1,20,000 (attendant charges), ₹1,68,970 (medical bills), and ₹50,000 (nutrition/transport).
   Total: ₹8,56,970.

3. High Court’s Enhancement (2019): Added ₹50,000 (pain/suffering), ₹1 lakh (loss of amenities), and ₹1 lakh (future treatment).

Issues Before the Supreme Court

1. Whether the legal heirs (husband and daughters) could pursue the claim after Meena’s death (25.01.2024).

2. Whether the compensation needed further enhancement.

Supreme Court’s Decision

1. Right of Legal Heirs:
   Cited Oriental Insurance Co. v. Jasmail Singh Kahlon (2022) to affirm that legal heirs can inherit claims for "loss to estate" even if the injured dies later.
   Allowed the appeal to proceed for enhancement.

2. Enhanced Compensation:
   Revised Calculation:
   Loss of Income: ₹5,14,800 (₹3,000 + 10% inflation × 12 months × 13 multiplier).
   Other Heads:
   Medical bills: ₹1,68,970
   Special diet/transport: ₹50,000
   Pain/suffering: ₹1,00,000
   Loss of amenities: ₹1,00,000
   Future treatment: ₹2,00,000 (additional ₹1 lakh)
   Attendant charges: ₹1,20,000
   Total Compensation: ₹12,53,770 (after deducting amounts already paid).

3. Directions:
   Insurance company to pay the balance to legal heirs equally within 2 months via online transfer.
   Interest as per Tribunal’s rate.

Conclusion

• The Supreme Court allowed the appeal, enhancing the total compensation to ₹12,53,770 and affirming the rights of legal heirs to pursue claims for losses incurred by the deceased claimant.

• The judgment reinforces precedents on the broader interpretation of "estate" under motor accident claims.

Final Disposal: Pending applications, if any, were closed.