Wider Interpretation of ‘Legal Representative’ Under Motor Vehicle Act
Last Updated on March 19, 2025 by Athi Venkatesh
The Supreme Court has clarified that the term ‘legal representative’ under the Motor Vehicles Act should not be narrowly interpreted. The Court ruled that dependents of the deceased, even if not immediate family like spouses, parents, or children, are entitled to compensation.
A bench of Justice Sanjay Karol and Justice Prashant Kumar Mishra heard the case Sadhana Tomar & Ors. v. Ashok Kushwaha & Ors. The Motor Accident Claims Tribunal (MACT) earlier denied compensation to the deceased’s father and sister. The Tribunal reasoned that the father was not dependent on the deceased’s income, and since he was alive, the younger sister couldn’t claim dependency either. The High Court upheld this finding.
Challenging this, the appellants approached the Supreme Court.
The apex court set aside the lower courts’ decisions. It observed that both courts erred in refusing to treat the deceased’s father and younger sister as dependents. Citing key precedents like Gujarat SRTC v. Ramanbhai Prabhatbhai and N. Jayasree v. Cholamandalam MS General Insurance Co., the Court emphasized that establishing loss of dependency is enough to claim compensation. The law does not limit compensation to only spouses, children, or parents but includes anyone who suffers due to the deceased’s death.
The Court held that under Chapter XII of the MV Act, a broader interpretation of ‘legal representative’ is necessary. It ruled that the father and younger sister, being financially dependent on the deceased, qualified as legal representatives.
Observing that the deceased ran a wholesale fruit business and financially supported the family, the Court awarded compensation to the appellants.
This ruling reiterates the Court’s stand that compensation should reach all dependents impacted by fatal motor accidents, not just immediate family members.
