Chhattisgarh HC rules non-dependent legal heirs can claim compensation in motor accident cases, dismissing insurer’s appeal

News Citation : 2026 LN (HC) 287 | 2026:CGHC:19942

April 29, 2026 : The Chhattisgarh High Court has upheld a compensation award granted to the elder brothers of a man who died in a road accident, ruling that even non-dependent legal representatives are entitled to claim compensation under the Motor Vehicles Act.

In its order dated April 29, 2026, Justice Sanjay Kumar Jaiswal dismissed an appeal filed by Shriram General Insurance Company Limited challenging a 2016 award passed by the Motor Accident Claims Tribunal (MACT), Dantewada. The Tribunal had granted ₹3.10 lakh in compensation, along with 6% annual interest, to the deceased’s brothers.

The case arose from a fatal accident on January 1, 2012, when a truck ran over a 25-year-old labourer, Baman, who was resting near a shop while waiting for transport. The vehicle was allegedly driven rashly, resulting in his death on the spot.

Following the incident, the deceased’s elder brothers filed a claim petition under the Motor Vehicles Act. The Tribunal assessed the victim’s monthly income at ₹3,000, applied a multiplier of 17, and after deducting 50% for personal expenses, awarded compensation along with nominal amounts for funeral expenses and loss of estate.

The insurance company argued before the High Court that the claimants, being married and financially independent, were not dependents of the deceased and therefore not entitled to compensation. It contended that the award was legally unsustainable and excessive.

Rejecting this argument, the High Court clarified that the term “legal representative” under the Motor Vehicles Act has a broad scope and is not limited to dependents alone. Relying on precedents from the Supreme Court, the court observed that even individuals who are not financially dependent on the deceased can claim compensation if they represent the estate of the deceased.

The court noted that since the deceased was unmarried and his parents had already passed away, his brothers qualified as legal heirs and legal representatives. Therefore, their claim could not be dismissed merely on the ground of lack of dependency.

On the question of quantum, the court found no merit in the insurer’s contention that the compensation was excessive. It held that the Tribunal had applied the correct principles and arrived at a reasonable figure based on the evidence on record.

Concluding that there was no legal or factual error in the Tribunal’s decision, the High Court dismissed the appeal and affirmed the compensation awarded to the claimants.

Case Reference : MAC No. 1141 of 2016, Shri Ram General Insurance Co. Ltd. v. Lachcha Muchaki & Ors.; Counsels: for the Appellant – Mr. Raghvendra Verma and Mr. Deepak Gupta, Advocates; for Respondents No. 3 & 4 – Mr. Vikas Patel, Advocate (on behalf of Mr. P.K. Tulsyan); for Respondents No. 1 & 2 – None.