In a significant ruling clarifying the purpose of compensation under motor accident laws, the Gujarat High Court has stated that such awards are "not a bonanza or a jackpot". The court made this observation while partly allowing an appeal for enhanced compensation but refusing to include over Rs 10.86 lakh in medical expenses already paid by a charitable trust.
Court Rejects Double Recovery for Trust-Paid Bills
Justice Hasmukh D Suthar, presiding over the case, delivered the order on January 8. The bench was hearing an appeal filed by the legal heirs of a man who died in a 2011 accident, seeking an increase in the compensation awarded by the Motor Accident Claims Tribunal (MACT).
The court firmly rejected the appellants' plea to include Rs 10,86,415 in their compensation amount. This sum represented medical bills that had been settled by the Shantaben Atmaramdas Patel Charitable Trust on behalf of the deceased during his treatment.
"Once expenses have already been incurred and paid by a third party, the claimants cannot seek to receive that amount again," Justice Suthar asserted. The court noted there was no evidence that the claimants themselves were entitled to receive that money, and in any case, they would owe it to the trust.
Background of the Tragic Accident and Initial Award
The case stemmed from a tragic road accident on April 1, 2011. The victim, along with a friend, was traveling by car to Balotara to attend a horse fair when their vehicle overturned. He sustained severe multiple injuries, including head fractures.
After initial treatment at a government hospital in Siddhpur, Patan, until June 3, 2011, he was moved to Sterling Hospital in Ahmedabad. He later continued treatment at home but ultimately succumbed to his injuries on February 28, 2012.
The MACT, in its award dated May 6, 2021, had granted compensation of Rs 41,05,240 with an annual interest rate of 7.5%. Dissatisfied with this quantum, the legal heirs appealed for enhancement under Section 173 of the Motor Vehicles Act.
Partial Enhancement Granted on Other Grounds
While rejecting the claim related to the trust's payment, the High Court found merit in other arguments presented by the appellants' advocate, Vishal Mehta. The court agreed that the tribunal had committed an error by overlooking medical bills worth Rs 2,52,899 dated after the victim's discharge from Sterling Hospital on June 23, 2011.
Regarding attendant and transportation charges, the court was skeptical of some duplicate or overlapping bills produced by the claimants. Justice Suthar declined to accept these documents "as a gospel truth" but awarded a lump sum of Rs 50,000 under this head.
A significant enhancement came under the head of loss of consortium. The tribunal had awarded only Rs 44,000 for the deceased's four dependants. Citing Supreme Court principles, the High Court revised this to Rs 1,93,600 (Rs 48,400 for each dependant).
Final Award and Insurance Company's Duty
After recalculating all admissible heads, the Gujarat High Court modified the MACT's award. The total compensation was enhanced from approximately Rs 41.05 lakh to Rs 45,57,739. The court maintained the interest rate of 7.5% per annum from the date of the original claim petition.
The appeal was accordingly partly allowed. The court directed the concerned insurance company to deposit the enhanced compensation amount within a period of four weeks.
Advocate Kirti Pathak, representing the insurance company, had opposed the appeal. She argued successfully that since the charitable trust itself had not claimed reimbursement, and the claimants had already received the benefit of its payment, they could not seek the same amount again as compensation.
This judgment reinforces the principle that compensation under the Motor Vehicles Act aims to restore the financial loss suffered by victims or their families, not to provide an unjust windfall.
