New India Assurance Company Ltd. Vs. Sonigra Juhi Uttamchand [Civil Appeal No.________ of 2025 @ SLP (C) No. 30491 of 2018]
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India, in New India Assurance Company Ltd. vs. Sonigra Juhi Uttamchand [Civil Appeal No. _______ of 2025 @ SLP (C) No. 30491 of 2018], delivered its judgment on January 2, 2025, addressing motor accident compensation claims involving the tragic death of the appellant’s family members in a road accident.
Facts and Background
The appellant, Sonigra Juhi Uttamchand, lost her parents and younger brother in a motor vehicle accident caused by a rash and negligent driver of a Tata van insured with the New India Assurance Company Ltd. The appellant filed three separate claims before the Motor Accident Claims Tribunal seeking compensation for the deaths of her father, mother, and brother. The Tribunal awarded compensation which was later enhanced by the High Court. The Insurance Company challenged the enhanced compensation before the Supreme Court, seeking reduction.
Legal Issues
The Supreme Court examined:
The correctness of the compensation amount fixed by the Tribunal and enhanced by the High Court.
The admissibility and reliability of Income Tax Returns as proof of the deceased’s income for calculating compensation.
Whether the High Court erred in not deducting one-third of the income while calculating compensation, as per the precedent in Sarla Verma vs. Delhi Transport Corporation.
The appropriateness of the enhanced compensation awarded considering the appellant’s young age and the loss suffered.
Court’s Analysis and Findings
The Court reiterated that Income Tax Returns, being statutory documents, are admissible and relevant evidence for determining the deceased’s income, provided the details of tax payments are properly brought on record to enable correct calculation of income. In this case, the deceased’s income was fixed at Rs. 1,98,192 per annum based on the Income Tax Returns for the relevant financial year.
The Court upheld the High Court’s enhanced compensation award, observing that the appellant was only 14 years old when she lost her family and would endure the hardship of such solitude for a long time. The Court found no reason to interfere with the quantum of compensation, noting that the difference between the original and enhanced amounts was not alarmingly excessive.
The Court also discussed the need to revisit compensation amounts every three years with a 10% enhancement, as laid down in National Insurance Co. Ltd. vs. Pranay Sethi and other precedents. While the High Court did not deduct one-third of the income while calculating the enhanced compensation as per Sarla Verma, the Court acknowledged the insurer’s contention but did not find it sufficient to reduce the compensation in this case.
Conclusion
The Supreme Court dismissed the Insurance Company’s appeal, affirming the enhanced compensation awarded to the appellant for the deaths of her parents and brother in the motor accident. The judgment highlights:
The acceptance of Income Tax Returns as valid evidence for income determination in motor accident claims, subject to proper proof of tax payment.
The principle of periodic enhancement of compensation amounts.
The Court’s sensitivity towards the claimant’s young age and the long-term impact of the loss suffered.
This ruling reinforces the protective approach of courts in awarding just compensation to victims of motor accidents and clarifies evidentiary standards for income assessment in such claims.
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