Can the family of a murder victim claim compensation under the Motor Vehicles Act (MVA) merely because the crime took place inside a motor vehicle? The Supreme Court has answered that question by drawing a fine but significant distinction between the commission of a crime inside a vehicle and an accident “arising out of the use of a motor vehicle”, holding that the mere presence of a vehicle in the chain of events is insufficient to attract liability under the Act.
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A bench of justices Sanjay Karol and Augustine George Masih held that a claimant seeking compensation under the MVA must establish a causal nexus between the use of the motor vehicle and the death or injury. Where that link is missing, compensation cannot be awarded merely because the offence was committed in, or involved, a vehicle.
The ruling came in a case where Anand,the deceased, had left in a car driven by a person known to him, Dilip, and was found dead three days later. The deceased’s family alleged that Anand was murdered while travelling in the vehicle and sought compensation under the MVA. While the Motor Accident Claims Tribunal and the high court accepted the claim, the Supreme Courtoverturned both decisions, finding no evidence to establish that the death had arisen out of the use of the vehicle.
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No evidence linking vehicle to death
The bench noted that the criminal prosecution itself had failed to establish the “last seen” theory against the accused and that there was no forensic material connecting the car to the murder. There was no evidence of blood stains, hair, skin cells or any indication that the vehicle had been involved in a collision or any other event resulting in the fatal injuries.
“Simply because there was a car somehow involved in a chain of circumstances that led to his death, the provisions of the MVA would apply. Some link whatsoever between the car, and the death has to be established,” the bench held in its July 22 judgment.
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Court explains ‘accidental murder’ principle
The judgment revisits an important line of precedent beginning with Rita Devi Vs New India Assurance Co Ltd (2000), where the Supreme Court had evolved the concept of an “accidental murder”. In that case, the court held that where murder is committed in furtherance of another felonious act, such as theft of a vehicle, it may still qualify as an accident under the MVA because the dominant intention was not to kill but to facilitate the theft.
Explaining that distinction, the bench quoted the 2000 verdict, which held that if “the dominant intention” is to kill a particular person, the offence is a murder simpliciter. However, if the killing occurs in furtherance of another crime, the murder may assume the character of an accidental murder for the purposes of compensation law.
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Mere presence of vehicle not enough
The bench, however, said that principle could not be mechanically applied to every case involving a vehicle.
“We are…of the considered view that this distinction between primary and secondary felonious act cannot be made in the present case,” noted the bench, pointing out that the record contained no evidence demonstrating how or where the fatal injuries were inflicted or that the vehicle itself played any role in causing the death.
The court also clarified the evidentiary threshold applicable before Motor Accident Claims Tribunals. Unlike criminal trials, where guilt must be established beyond reasonable doubt, compensation proceedings are decided on the civil standard of “preponderance of probabilities”. Even under this relatively lower standard, however, the claimant must prove a sufficient nexus between the accident and the use of the motor vehicle.
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Relying on a string of earlier decisions including, the bench reiterated that strict proof of the manner of the accident is unnecessary in compensation proceedings, but some credible evidence connecting the vehicle to the injury or death must nevertheless exist.
Finding that no such connection had been established in the present case, the bench allowed the insurer’s appeals and set aside the judgments of the tribunal and the high court. At the same time, considering the peculiar facts of the case, it directed that the compensation already disbursed to the deceased’s family should not be recovered.
