LexTHE ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED versus SMT. HONNAMMA & ORS.
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[2025] 6 S.C.R. 141 : 2025 INSC 625 The Royal Sundaram Alliance Insurance Company Limited v. Smt. Honnamma & Ors. R1: Smt. Honnamma R2: Kum. Bhagya R3: Kum. Ramya R4: Sri H. Nagaraj (Civil Appeal No. 6336 of 2025) 05 May 2025 [Sudhanshu Dhulia and Ahsanuddin Amanullah,* JJ.] Issue for Consideration Matter pertains to the correctness of the order passed by the High Court partly allowing the appeal of the respondents, enhancing the compensation and fastening the liability on the insurance company. Headnotes† Motor Vehicles Act, 1988 – s.147 – Fatal accident – Compensation – Liability of the insurance company – Tractor insured with the appellant-insurance company attached to a trailer, and due to rash and negligent driving of the driver, tractor and trailer toppled, person on the trailer, fell off the trailer, resulting in his death – Claimants-wife and minor daughters claimed compensation – Tribunal granted compensation of Rs.9,50,000/- and held that risk of employee of the tractor and trailer was not statutorily covered and fastened the liability to satisfy the award on the owner and the driver – Claimants sought enhancement of compensation – High Court enhanced compensation to Rs.13,28,940/- and fastened the liability of compensation on the appellant – Correctness: Held: 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 * Author 142 [2025] 6 S.C.R. Supreme Court Reports of events which cannot be segregated or compartmentalized – Court is duty-bound to be mindful of the ground realities and cannot let practicality be overshadowed by technicality – On facts, 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 – Thus, the accident was caused by the tractor, as during the course of being driven/pulled by the tractor, the accident occurred – Liability of the tractor/its insurer extended to the accident caused by the tractor resulting in the death of the deceased, through the trailer – Appellant 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, whichever be the higher amount of the two – Amount exclusively payable by the appellant, however, in no case be less than Rs.9,50,000/- – No infirmity in the impugned order, either with regard to the quantum of compensation awarded or fixation of liability on the insurer-appellant for the accident. [Paras 11, 12, 18, 19] Case Law Cited United India Insurance Co. Ltd., Kadapa District v. Koduru Bhagyamma, 2007 SCC OnLine AP 830 – approved. Sarla Verma v. Delhi Transport Corporation [2009] 5 SCR 1098 : (2009) 6 SCC 121; New India Assurance Co. Ltd. v. C M Jaya [2002] 1 SCR 298 : (2002) 2 SCC 278; Dhondubai v. Hanmantappa Bandappa Gandigude Since Deceased Through His LRs & Ors. Civil Appeal Nos. 5459-5460/2023; Ningamma v. United India Insurance Co. Ltd. [2009] 8 SCR 683 : (2009) 13 SCC 710; K Ramya v. National Insurance Co. Ltd. [2022] 18 SCR 238 : 2022 SCC OnLine SC 1338; Shivaleela v. Divisional Manager, United India Insurance Co. Ltd. [2025] 4 SCR 63 : 2025 SCC OnLine SC 563; Oriental Insurance Co. Limited v. Brij Mohan [2007] 6 SCR 843 : (2007) 7 SCC 56; New India Assurance Co. Ltd. v. Shantibai [1995] 1 SCR 871 : (1995) 2 SCC 539; Amrit Lal Sood v. Kaushalya Thapar [1998] 2 SCR 284 : (1998) 3 SCC 744 – referred to. List of Acts Motor Vehicles Act, 1988. [2025] 6 S.C.R. 143 The Royal Sundaram Alliance Insurance Company Limited v. Smt. Honnamma & Ors. List of Keywords Motor accident; Death; Compensation; Beneficial and welfare- oriented legislation; Liability of insurance company; Trailer attached to tractor; Chain of events; Root cause of accident; Events which cannot be segregated or compartmentalised; Maximum amount payable; Recover differential amount; Total compensation awarded less maximum amount payable; Enhancement of compensation; Rash and negligent driving of the driver; Fixation of liability on the insurer for the accident. Case Arising From CIVIL APPELLATE JURISDICTION: Civil Appeal No. 6336 of 2025 From the Judgment and Order dated 25.11.2022 of the High Court of Karnataka at Bengaluru in MFA No. 3659 of 2014
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