Summary of the Judgment Suhagrani and Others vs. Manager Cholamandalam MS General Insurance Co. Ltd

Case Name: Suhagrani and Others vs. Manager Cholamandalam MS General Insurance Co. Ltd.

Citation:
2025 INSC 837

Judges:

• J.K. Maheshwari

• Aravind Kumar

Date of Judgment:
July 14, 2025

Related Law:
Motor Vehicles Act, 1988 (Sections 166 and 173) – Pertaining to compensation claims for motor vehicle accidents.

Background and Issue

The Supreme Court addressed an appeal challenging the Madhya Pradesh High Court’s decision to overturn a Motor Accident Claims Tribunal (MACT) award. The key issue was whether the claimants (appellants) were entitled to compensation for the death of Nathuram Ahirwar in a motor vehicle accident allegedly caused by negligence, and whether the High Court erred in dismissing their claim.

Key Facts

1. Accident Details:
   On 24.09.2021, Nathuram Ahirwar (deceased) was riding a motorcycle with his wife (claimant No. 1) as a pillion rider when a mini-truck (Ape vehicle) hit them from behind.
   The deceased succumbed to injuries on 01.10.2021.

2. Claims Tribunal’s Decision (MACT):
   Awarded Rs. 12,43,324/- as compensation with 6% interest, holding the mini-truck driver negligent.

3. High Court’s Reversal:
   Overturned the MACT’s decision, citing inconsistencies in witness testimonies (e.g., PW-2’s police statement suggested the deceased fell due to imbalance, not the mini-truck).
   Doubted the claimants’ version due to non-examination of the son-in-law (alleged eyewitness).

Supreme Court’s Analysis

1. Evidence Re-evaluated:
   PW-1 (Wife of Deceased): As an eyewitness, she consistently testified that the mini-truck caused the accident. Her trauma and delayed complaint were justifiable.
   PW-2 (Son of Deceased): Denied giving a contradictory statement to the police (Exhibit D-1). The insurer failed to prove Exhibit D-1’s authenticity by examining the investigating officer.
   Documentary Evidence: FIR (Exhibit P-8), medical reports (Exhibit P-2), and charge sheet against the mini-truck driver corroborated the claimants’ version.

2. High Court’s Errors:
   Ignored PW-1’s credible testimony and over-relied on unproven contradictions in PW-2’s statement.
   Failed to consider the charge sheet filed against the mini-truck driver, which supported negligence.

3. Compensation:
   The appellants sought enhancement, claiming the deceased earned Rs. 10–20 lakhs annually from agriculture. The Court rejected this due to lack of evidence but upheld the MACT’s award as reasonable.
   Modified Apportionment: 85% to the widow (claimant No. 1) and 15% equally to the adult children (claimants 2–4).

Conclusion

• The Supreme Court allowed the appeal in part, restoring the MACT’s compensation award but modifying the apportionment.

• The High Court’s judgment was set aside for disregarding material evidence and misinterpreting witness testimonies.

• No costs were awarded.

Final Order:

• Compensation of Rs. 12,43,324/- with 6% interest upheld.

• Apportionment: 85% to the widow, 15% to the children.