The Supreme Court of India has upheld a Karnataka High Court decision that held the legal heirs of a person who died due to their own rash and negligent driving are not entitled to claim compensation under the Motor Vehicles Act, 1988. The case, G Nagarathna & Ors. vs. G Manjunatha & Anr., involved a tragic incident where N.S. Ravisha died after losing control of a car he was driving at excessive speed. His family filed a claim for ₹80 lakh under Section 166 of the Motor Vehicles Act, but the Motor Accidents Claims Tribunal (MACT) rejected the claim, citing that Ravisha was the tortfeasor and had caused the accident through his own negligence.
The family appealed to the Karnataka High Court, which upheld the Tribunal’s decision, citing settled Supreme Court precedent that precludes a tortfeasor or their legal representatives from recovering compensation for injury or death resulting from their own negligence. The Supreme Court relied on key precedents, including Ningamma & Ors. v. United India Insurance Co. Ltd. and Minu B. Mehta v. Balkrishna Nayan, to dismiss the appeal and uphold the High Court’s decision.
The Court emphasized that tort law treats a borrower as an owner because by taking control and possession of the vehicle, the borrower assumes the same responsibilities and risks as the owner, including the duty to drive safely. Awarding compensation in such circumstances would be contrary to the fundamental principle that no person should derive benefit from their own wrong. The ruling does not affect claims by third parties injured due to the deceased’s negligence, as the insurer would still be liable for valid third-party claims under the Motor Vehicles Act.
The implications of this ruling are significant, as it reiterates that a tortfeasor or their legal heirs cannot claim damages for losses directly attributable to their own negligence. For claimants, it underscores the necessity of proving that the deceased was not responsible for the accident. For insurers, it provides a strong defense against claims where the insured’s own wrongful conduct caused the fatality, ensuring that insurance does not become a backdoor means to profit from reckless driving.
From a policy perspective, the judgment aligns statutory law with fundamental tort principles and safeguards public interest by discouraging reckless driving and misuse of the compensation framework. It ensures the compensation mechanism does not become an unintended incentive for unlawful behavior on the roads. The Supreme Court’s dismissal of the SLP in G Nagarathna & Ors. vs. G Manjunatha & Anr. is a timely reminder that the principle “no man shall profit from his own wrong” is an enforceable legal doctrine, promoting responsible driving and safeguarding the integrity of the insurance system.