Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-006621-006621 – 2025 |
| Diary Number | 4952/2020 |
| Judge Name | HON’BLE MR. JUSTICE K. VINOD CHANDRAN |
| Bench | HON’BLE MR. JUSTICE K. VINOD CHANDRAN and HON’BLE MR. JUSTICE N.V. ANJARIA |
| Precedent Value | Binding on subordinate courts |
| Overrules / Affirms | Affirms High Court judgment |
| Type of Law | Motor accident compensation (civil law) |
| Questions of Law | Whether death occurring months after an accident can be directly attributed to the accident absent conclusive medical proof |
| Ratio Decidendi |
The Court held that mere temporal proximity between accident and death is insufficient for causation; a direct nexus must be established on a preponderance of probability through clear expert medical evidence. Comorbidities and absence of postmortem further weaken any causal link. The High Court’s scrutiny of medical testimony and records was unimpeachable. |
| Logic / Jurisprudence / Authorities Relied Upon |
|
| Facts as Summarised by the Court | Deceased collided on 29.04.2006; inpatient till 03.05.2006; outpatient till 12.08.2006; referred for plastic surgery on 18.09.2006; underwent skin grafting on 21.09.2006; died same day of pulmonary embolism/acute myocardial infarction. |
| Citations | 2025 INSC 1075 (Non-Reportable) |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts |
| Persuasive For | High Courts |
| ✔ Precedent Followed | Requirement of clear causal nexus in death claims upheld |
What’s New / What Lawyers Should Note
- Clarifies that mere temporal proximity between accident and death is insufficient to establish causation.
- Emphasises the necessity of detailed expert medical evidence to demonstrate a direct nexus.
- Highlights that comorbidities (e.g., diabetes, hypertension, high cholesterol) critically influence causation analysis.
- Confirms that the absence of a postmortem report significantly weakens a compensation claim for death.
- Reinforces application of the preponderance of probability standard in motor accident causation disputes.
Summary of Legal Reasoning
- The Tribunal found that the non-healing ulcer and eventual death flowed directly from the accident injuries.
- The High Court closely examined PW-1’s testimony (Exhibits A-1 and A-9), noting admissions about comorbid conditions and high cholesterol.
- Lack of a postmortem report and no documented period of extended bed rest undermined the causal link.
- The Court held that temporal proximity alone cannot satisfy causation without clear expert proof.
- The Supreme Court upheld the High Court’s application of the preponderance of probability standard and dismissed the appeal.
Arguments by the Parties
Petitioner (Claimants)
- The non-healing ulcer and death were direct consequences of the accident.
- Temporal proximity and the medical certificate (Exhibit A-1) establish causation.
- The victim had no prior ailments; long bed rest due to accident injuries precipitated pulmonary embolism/MI.
Respondent (Insurer)
- Accident injuries were not serious enough to cause death.
- PW-1’s cross-examination revealed pre-existing conditions: mild hypertension, diabetes, high cholesterol.
- No postmortem was conducted, leaving true cause of death uncertain.
- Death could be an after-effect of surgery or comorbidities, not the accident.
Factual Background
On 29.04.2006 an excise guard’s motorcycle collided with another. He was treated as an inpatient until 03.05.2006 and as an outpatient until 12.08.2006. Referred on 18.09.2006 for plastic surgery due to a non-healing ulcer, he underwent skin grafting on 21.09.2006, developed sudden breathlessness, and died of pulmonary embolism/acute myocardial infarction the same day—nearly five months after the accident.
Alert Indicators
- ✔ Precedent Followed – Existing standard requiring clear causative nexus and expert proof in motor accident death claims upheld.
Citations
- 2025 INSC 1075, Non-Reportable
- Civil Appeal No. 6621 of 2025