2026 INSC 950 | 3 September 2026 — Reliance General Insurance Company Limited v. Priyanka Das and Others
What the case was about
The case reached the Supreme Court as cross-appeals from the Punjab and Haryana High Court. Reliance General Insurance Company Limited, the insurer of the offending vehicle, challenged the quantum of compensation awarded by the Motor Accident Claims Tribunal (MACT), Gurugram, which had been marginally modified by the High Court. Priyanka Das, who had filed the claim petition seeking Rs 5 crore in compensation for the death of Sushant Prabhakaran, challenged the refusal of both forums to recognise her as his legally wedded wife. The Tribunal had awarded a total of Rs 82,56,152, giving only a small share to Das while apportioning the bulk to Prabhakaran’s parents.
The key facts
In April 2011 near Brijghat Bridge, a heavy goods vehicle hit a motorcycle, killing its 33-year-old rider, Sushant Prabhakaran, and grievously injuring the pillion passenger, Priyanka Das. FIR No. 198 was registered. Das subsequently filed MACT Petition No. 9 of 2014 asserting that she was Prabhakaran’s widow and therefore entitled to the major share of the dependency compensation. The Tribunal, however, noted the complete absence of documentary evidence of marriage and relied on employment records in which Das herself had listed the deceased as her “fiancé.” It concluded that she was not financially dependent on him, treated her as a fiancée rather than a spouse, and apportioned only Rs 5,00,000 to her while awarding the remainder to his parents. The High Court increased her share marginally to Rs 7,50,000 but otherwise left the award and the underlying findings undisturbed.
The questions before the Court
The bench of Justices S.V.N. Bhatti and N.V. Anjaria was asked to decide three issues. First, whether the accident was proved to have been caused by the rash and negligent driving of the truck driver. Second, whether the multiplier used to calculate loss of dependency should be pegged to the age of the deceased or to the age of his dependent parents. Third, whether Priyanka Das had discharged the burden of proving that she was Prabhakaran’s legally wedded wife, and whether the apportionment of compensation should be reopened.
What the Court decided and why
Negligence upheld. The Court noted that the MACT proceedings are summary in nature and that negligence is assessed on the “preponderance of probabilities,” not the criminal standard of proof beyond reasonable doubt (para 12). It observed that the insurer had not seriously challenged the concurrent findings of fact recorded by the Tribunal and the High Court. The testimony of eyewitness PW-9, coupled with the admissions of the truck driver examined as RW-2 and the contents of the chargesheet in FIR No. 198, sufficed to sustain the finding that the accident resulted from the driver’s rash and negligent conduct (para 12).
Multiplier must follow the deceased’s age. The insurer argued that because the compensation was ultimately being paid to the deceased’s parents, the multiplier should correspond to their age rather than to Prabhakaran’s 33 years. The Court flatly rejected this contention, holding that the law on this point is “no longer res integra” (para 13). It cited the standardised multiplier matrix laid down in Sarla Verma v. Delhi Transport Corporation — subsequently validated by a Five-Judge Bench in National Insurance Co. Ltd. v. Pranay Sethi — and the rulings in Munna Lal Jain v. Vipin Kumar Sharma and Sube Singh v. Shyam Singh to reaffirm that the multiplier depends on the age of the deceased, not on the age of the dependents (paras 13–14). Because Prabhakaran was 33, the correct multiplier was 16, corresponding to the 31-to-35 age bracket in the Sarla Verma table. Both the Tribunal and the High Court had therefore applied the correct figure (para 14).
Marital status claim rejected. On the question of whether Das was the legally wedded wife, the Court emphasised that the burden of proof lay squarely on her, even in summary proceedings (para 15). The Tribunal and the High Court had carefully scrutinised the oral and documentary evidence and found no proof of marriage; instead, employment records showed that Das had listed the deceased as her fiancé. Declining to reappreciate the evidence or disturb concurrent findings of fact that were not perverse, the Supreme Court affirmed that Das had failed to discharge her burden (para 15). It also held that the apportionment followed binding precedents and did not warrant interference (para 15).
Both civil appeals — one by the insurer and one by the claimant — were dismissed (para 16). The Court made no order as to costs (para 17).
Why it matters
The ruling is a reiteration of two settled but frequently contested principles in Indian motor accident jurisprudence. By insisting that the multiplier is tethered to the age of the deceased victim, the Court has reinforced the predictability and uniformity of compensation awards across the country, foreclosing attempts by insurers to reduce payouts by pointing to the advanced age of dependents. At the same time, the judgment serves as a reminder that claimants who assert spousal status must produce concrete documentary proof; mere oral assertion, or even employment-related records that list the relationship differently, will not suffice when the record points elsewhere. Finally, the decision illustrates the Supreme Court’s reluctance to second-guess concurrent factual findings rendered by Tribunals and High Courts in summary accident proceedings unless they are demonstrably perverse. The rules on compensation calculation are now standardised, but claims to family status must be evidenced, not assumed.