In an accident chain, the liability under MV Act would pass on to the vehicle which was the root cause of the accident – Supreme Court
In a recent judgment, Hon’ble Supreme Court has held that if an insured vehicle hits another vehicle which in turn hits a third vehicle, then for the entire chain of accidents, the liability would pass on to the vehicle which was the root cause of the accident because it is the result of the action in the same chain of events which cannot be segregated or compartmentalized
ABCAUS Case Law Citation:
4547 (2025) (05) abcaus.in SC
In the present case, an incident occurred while a tractor which was insured with the Insurance company was attached to a trailer and on the trailer the deceased was travelling as a coolie in order to unload the soil. Due to the rash and negligent driving, the tractor and trailer toppled causing injuries to the deceased ultimately leading to his death.
The wife and two minor daughters (Respondents/Claimants) filed a case before the MACT claiming a compensation of Rs.10,00,000/-. The MACT after considering the evidence on record, partly allowed the claim and awarded a compensation of Rs. 9,50,000/- with interest at 6% per annum from the date of filing of the petition till its realization. The MACT held that the risk of employee of the tractor and trailer was not statutorily covered under Section 147(1)(b) of the Motor Vehicles Act, 1988 (the MV Act) and fastened the liability to satisfy the award on the owner and the driver.
On the appeal of the claimants the High Court vide the Impugned Order partly allowed the appeal and enhanced the compensation. The High Court fastened the liability of compensation on the Appellant-insurance company. Aggrieved thereby, the Appellant Insurance company had approached the Hon’ble Supreme Court.
The Hon’ble Supreme Court observed that the undisputed position was that the trailer was being pulled by/attached to the tractor and then the trailer on which the deceased was present, turned turtle/upturned, resulting in his death. The tractor which was insured was the reason for the accident. It was not the case that only because of some fault on the part of the trailer stand-alone, the accident happened. To explain, we may give an example: that had the trailer been stationary at a place and due to some reason, it overturned or a mishap happened, then without the trailer being specifically insured the Appellant would not be liable to pay, but the main cause of the accident was the tractor which was pulling/driving moving the trailer and in such sequence of events, the trailer upturned. The accident was caused by the tractor, as during the course of being driven/pulled by the tractor, the accident occurred.
The Hon’ble Supreme Court held that the liability of the tractor/its insurer extended to the accident caused by the tractor resulting in the death of the deceased, through the trailer. In view of the facts of the case, the principles emanating from the decisions where the Courts have held that the trailer has to be separately registered with the insurance company to make it liable, would not be applicable.
The Hon’ble Supreme Court held that ultimately the root cause of the accident being the tractor, which was insured, this crucial fact cannot be lost sight of. It might be illustrated as if an insured vehicle hits another vehicle which in turn hits a third vehicle, then for the entire chain of accidents, the liability would pass on to the vehicle which was the root cause of the accident because it is the result of the action in the same chain of events which cannot be segregated or compartmentalized. Moreover, the Court is duty-bound to be mindful of the ground realities of the country and cannot let practicality be overshadowed by technicality.
However, the Hon’ble Supreme Court held that the Insurance company ought not to be saddled with payment of compensation exceeding what the insurance policy provides for or the limit, if any, set under any law for the time being in force, whichever be the higher amount of the two, in the underlying factual scenario.
Accordingly, the appeal was dismissed.
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