Authority: Supreme Court of India (Civil Appellate Jurisdiction)

Order Date: 09 October 2026

Case Overview

  • Parties: Appellant Manoj (owner and driver of the offending vehicle) vs. Respondent Sushmabai (claimant) and Respondent No.2 IFFCO Tokio General Insurance Company Ltd.
  • Origin: Appeal under SLP(C) No.2793 of 2026 against the High Court of Madhya Pradesh order dated 11 March 2025 (Misc. Appeal No.5927 of 2024), which had dismissed Manoj's challenge to the Motor Accident Claims Tribunal (MACT) award dated 15 September 2023 (MACC/261/2022).
  • Dispute: Whether the insurance policy issued by IFFCO Tokio covered a person other than the driver, i.e., a passenger, given that the vehicle’s Registration Certificate recorded a seating capacity of 1+1 while the policy recorded the capacity as one.
  • Arguments: The appellant contended that the policy’s seating‑capacity figure was factually incorrect and that the deceased passenger was injured due to the vehicle, thus should be covered. The insurer argued that the policy covered only the driver because the vehicle was not a commercial one and the passenger was neither a conductor nor a driver.
  • Court’s Reasoning: The Court observed that the Registration Certificate unequivocally shows a seating capacity of 1+1; the policy’s reference to the certificate makes the recorded “one” inaccurate. It noted the direct nexus that the deceased was seated on the tractor, fell, and his head came under the wheels, establishing that the accident was caused by the vehicle. The Court rejected a strict technical interpretation and held that the passenger is deemed covered under the insurance policy in the facts and circumstances of the case.

Final Outcome

  • The Supreme Court allowed the appeal.
  • The MACT award of Rs 9,94,056 plus interest at 6% per annum to Sushmabai is maintained.
  • Liability to pay the compensation is shifted from the appellant to IFFCO Tokio General Insurance Company Ltd.; the appellant is absolved of payment responsibility.
  • All pending applications, if any, are disposed of.

Topics: Insurance Liability, Supreme Court Judgment