Summary

Seema Rani & Ors. vs. Oriental Insurance Co. Ltd.

Case Citation: 2025 INSC 192
Court: Supreme Court of India
Issue: Dependents' rights in motor accident claims.
Judgment: The Supreme Court overruled the High Court’s exclusion of major children as dependents and recalculated compensation accordingly.

Summary :

The case involved a fatal road accident where the deceased, a government employee, was killed in a collision with a negligent bus driver. The claimants—his wife, daughter, and two sons—sought Rs. 50 lakh in compensation.

The tribunal awarded Rs. 24.36 lakh, considering only the wife as a dependent and deducting one-fourth of the deceased’s income. The High Court slightly increased the award but reduced dependency deductions, ruling that major children were not dependents.

The Supreme Court overturned this finding, emphasizing that dependency is not solely determined by age or employment status. It applied relevant precedents and recalculated compensation, recognizing all claimants as dependents. The final award was Rs. 37.80 lakh. 

Key Points:

• The High Court had deducted 50% of the deceased’s income, ruling that major children were not dependents.

• The Supreme Court reinstated them as dependents, citing National Insurance Co. Ltd. v. Birender.

• Final compensation increased from ₹24.44 lakh to ₹37.80 lakh.

Analysis:
The judgment emphasizes that dependency should not be rigidly linked to age or employment status but assessed based on actual financial reliance. It sets a precedent for broader inclusion in compensation claims.