Summary and Analysis of Urmila Chand vs Sonu Chand 2025 INSC 1072

1. Heading of the Judgment

Urmila Chand vs. Sonu Chand and Others
Civil Appeal No. 1352 of 2023
Supreme Court of India
Decided on September 3, 2025
Citation: (2025) INSC 1072

The case titled Urmila Chand vs. Sonu Chand and Others pertains to a civil appeal challenging the order of the Gauhati High Court, which had upheld the dismissal of a review petition by the Motor Vehicle Claims Tribunal, Tinsukia. The core issue revolved around the disbursement of compensation following a motor accident claim and the subsequent delay in filing a review against the apportionment.

2. Relevant Legal Provisions

The judgment engages with the following legal frameworks:

• Motor Vehicles Act, 1988: Governs the award and disbursement of compensation in accident claims.

• Limitation Act, 1963 – Section 5: Pertains to the condonation of delay in filing applications.

• Code of Civil Procedure, 1908 – Order 47, Rule 1: Provides grounds for review of judicial orders.

• Principles of Estoppel and Acquiescence: Judicial doctrines preventing a party from asserting a right after voluntary acceptance of benefits.

• Right to Information Act, 2005: Used by the appellant to gather case details.

3. Basic Details of the Case

• Appellant: Urmila Chand (mother of the deceased).

• Respondents: Sonu Chand (daughter-in-law) and two minor grandchildren.

• Background: The case arose from a fatal motor accident on February 27, 2009, involving Priyank Chand. The Motor Vehicle Claims Tribunal awarded a total compensation of ₹11,82,000 to the legal heirs. The disbursement was made via order dated April 21, 2015, allocating ₹1,00,000 to the appellant, ₹6,26,000 to the daughter-in-law, and ₹3,00,000 each to the minors in fixed deposits.

• Procedural History: The appellant filed a review petition against the disbursement order after a delay of 6 months and 22 days, which was dismissed by the Tribunal and later by the High Court.

4. Supreme Court’s Directions and In-Depth Analysis

A. Direction on Condonation of Delay

The Supreme Court affirmed the lower courts’ refusal to condone the delay in filing the review petition. The appellant cited medical surgery as the reason for the delay but failed to produce any documentary evidence to substantiate her claim. The Court emphasized that delays must be explained with sufficient cause under Section 5 of the Limitation Act, and mere assertions without proof are insufficient.

B. Direction on Estoppel and Voluntary Conduct

The Court held that the appellant’s conduct estopped her from challenging the disbursement order. Key observations included:

• The appellant had signed a joint application (No. 223 of 2015) along with other claimants, seeking disbursement of the awarded amount without specifying shares.

• She voluntarily accepted a cheque of ₹1,00,000, encashed it, and signed the Tribunal’s order sheet acknowledging receipt.

• She did not raise any objection at the time of disbursement and only later alleged unfairness.

The Court invoked the doctrine of approbation and reprobation, preventing a party from accepting benefits under an order and later challenging its validity.

C. Direction on Fraud and Unfairness

The appellant alleged that the disbursement was fraudulent and unfair, arguing that as a Class I legal heir, she deserved a larger share. The Court rejected this contention, noting:

• There was no evidence of fraud, coercion, or misrepresentation.

• The disbursement was based on a joint request by all claimants, including the appellant.

• The appellant’s subsequent dissatisfaction did not invalidate her prior voluntary actions.

D. Direction on Judicial Discretion in Review

The Court reiterated that review petitions are not avenues for re-hearing matters on merits. A review is permissible only on grounds of error apparent on the face of the record or discovery of new evidence. The appellant failed to establish any such ground.

E. Direction on Role of Tribunals and High Courts

The Supreme Court endorsed the approach of the Tribunal and High Court in:

• Scrutinizing the appellant’s conduct and the chronology of events.

• Relying on factual records, such as the signed order sheet and joint application, to conclude that the appellant had full knowledge of the disbursement.

5. Conclusion

The Supreme Court dismissed the appeal, upholding the decisions of the lower courts. It emphasized that:

• Delays in legal proceedings must be justified with credible evidence.

• Parties cannot resile from their voluntary and conscious actions.

• Claims of fraud must be substantiated with specific evidence.

• Judicial orders, especially those based on joint requests, cannot be lightly set aside on mere afterthoughts.

This judgment reinforces the importance of finality in judicial proceedings and the principles of equity and estoppel in contractual and legal conduct.