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Justice Sanjay K. Agrawal

Chhattisgarh High Court Caps Compensation in 2018 Motor Accident Case Following Supreme Court Precedent

News Citation : 2026 LN (HC) 247 | 2026:CGHC:16679

April 10, 2026 : In a significant ruling, the High Court of Chhattisgarh at Bilaspur has modified a compensation award for a 2018 motor accident, aligning the payout with the structured formula established by recent legal amendments and Supreme Court guidance. The decision, delivered by Justice Sanjay K. Agrawal, clarifies the retrospective application of beneficial legislation in motor accident claims.

The case originated from a fatal accident occurring on April 13, 2018, involving a motorcycle registered in Chhattisgarh. Following the tragedy, the Motor Accident Claims Tribunal (MACT) in Jashpur had initially awarded the claimants Smt. Seetamuni and others a sum of ₹6,94,599 plus interest. This award was challenged by the National Insurance Company Limited, which argued that the compensation exceeded the statutory limits set by the May 22, 2018, amendment to Section 163-A of the Motor Vehicles Act.

During the proceedings, the appellant’s counsel, Mr. Anil Gulati, pointed out that the amended schedule fixed the compensation for fatal accidents at a flat rate of ₹5,00,000. The core legal question was whether an amendment published in May could apply to an accident that happened just a month prior in April.

Justice Agrawal referenced the Supreme Court’s decision in New India Assurance Co. Ltd. v. Urmila Halder, which established that such amendments constitute beneficial legislation. The High Court noted that in the absence of a specific bar, the benefits of updated computational modalities should be passed on to the claimants. Consequently, the Court determined that the fixed ₹5,00,000 limit was applicable.

However, the Court also took into account the provision for annual increases. Under the 2018 notification, compensation amounts are set to increase by 5% annually starting from January 1, 2019. Calculating this annual increment over the eight years since the provision took effect, the Court added ₹40,000 to the base amount.

Ultimately, the High Court reduced the original award to a total of ₹5,40,000. This sum will carry an interest rate of 6% per annum, effective from the date the claim was initially filed in early 2019. The Registry has been directed to communicate this order directly to the claimants, as they were not represented during the appeal hearing, and the insurance provider has been given 45 days to deposit the remaining balance.

Case Reference : MAC No. 2314 of 2019: National Insurance Company Limited vs. Smt. Seetamuni and Others; Counsels: Mr. Anil Gulati for Appellant, Respondents unrepresented.