Rajasthan High Court Quashes Dual Compensation Awards in Road Accident Cases
Jaipur: In a significant ruling that clarifies compensation procedures for accident victims, a single-judge bench of the Rajasthan High Court has quashed compensation awards paid a second time to dependants of a person killed in an accident and two others injured in separate road accidents. The court held that pursuing dual claims for the same accident constitutes a manifest abuse of the process of law.
Court's Ruling on Election of Remedies
While allowing civil appeals filed by the National Insurance Company Ltd, Justice Anoop Kumar Dhand, in the judgment delivered on January 28, emphasized that under Section 167 of the Motor Vehicles Act, 1988, claimants must make an election of remedies. This means they cannot claim compensation both under the Motor Vehicles Act and the Workmen’s Compensation Act, 1923, for the same incident.
The court's decision underscores the legal principle that claimants must choose one statutory framework for seeking redress, preventing overlapping claims that could lead to unjust enrichment and burden the insurance system.
Background of the Cases
Both cases originated from separate road accidents in Rajasthan. In the first accident, which occurred on April 21, 2009, Jagdish Raiger was killed. His dependants—Manju Bai, Kumari Kisna, and Lakki—were initially awarded Rs 4.44 lakh by the Motor Accident Claims Tribunal (MACT) in Bundi under the Motor Vehicles Act.
In the second case, involving an accident on January 29, 2003, several individuals, including Kamli Devi, Leelaram, Dholaram, Kumari China, and Kumari Krishna, sustained injuries. The MACT in Jaipur City awarded them Rs 4.43 lakh under the same Act.
Dual Claims and Court's Directive
Despite receiving these awards under the Motor Vehicles Act, the claimants in both cases later filed separate compensation petitions under the Workmen’s Compensation Act before the Workmen’s Compensation Commissioners at Bundi and Jaipur. These petitions were allowed, granting additional compensation of Rs 4.11 lakh and Rs 2.95 lakh, respectively, along with interest.
The Rajasthan High Court, in its judgment, directed the claimants to refund the amounts received under the Workmen’s Compensation Act to the National Insurance Company Ltd forthwith, with usual interest. The court firmly dismissed the notion that compensation from one forum could be "adjusted" against that of another, reinforcing the need for strict adherence to legal procedures.
This ruling is expected to set a precedent for similar cases, ensuring that compensation claims are handled efficiently and without duplication, thereby protecting the interests of insurance companies and maintaining the integrity of the legal process.
