The Karnataka High Court has ruled that a second wife and her daughter can be entitled to compensation in a motor accident death claim if they were financially dependent on the deceased, underscoring that dependency—not merely legal status—plays a crucial role in determining eligibility for compensation.
A Division Bench comprising Justices Jayant Banerji and Tara Vitasta Ganju delivered the ruling while enhancing a compensation award by more than ₹15 lakh. The Court observed that the category of “legal representatives” under the Motor Vehicles Act cannot be narrowly restricted to a spouse, parent, or child recognized through a rigid legal framework.
The case arose after the death of a flower-crop farmer in a road accident involving a vehicle insured by National Insurance Company. Compensation claims were filed by the deceased’s first wife and mother. A separate claim was also presented on behalf of a woman identified as his second wife and her minor daughter.
While the Court did not examine or conclusively determine the validity of the second marriage, it found that both the woman and the child were dependent on the deceased. That factor, the Bench said, was sufficient to bring them within the scope of beneficiaries entitled to compensation.
Referring to Supreme Court jurisprudence on the Motor Vehicles Act, the High Court noted that the expression “legal representative” should receive a broad and purposive interpretation. The law, it said, is intended to provide relief to all those who genuinely suffer financial loss and hardship due to the death of a person in a motor vehicle accident.
The Bench emphasized that establishing dependency is the key requirement. Any person who can demonstrate that they relied on the deceased and suffered because of the death may seek compensation under the Act.
The Court also rejected the notion that deductions towards a deceased person’s personal expenses should follow a fixed formula based solely on family relationships. Such calculations, it observed, must depend on the specific facts of each case.
Another significant aspect of the ruling concerned the deceased’s income. The Motor Accident Claims Tribunal had assessed his monthly notional income at ₹10,000. The High Court found this figure inconsistent with the standard notional income applicable for 2019 and revised it to ₹14,000 per month. Taking this correction into account, along with the dependency of the second wife and daughter, the Court recalculated the compensation.
As a result, the insurer was directed to pay an enhanced compensation amount of ₹15,02,400, together with interest at 9 percent per annum, to the four claimants.
The judgment reinforces a growing judicial trend that places the realities of financial dependence above strict labels when awarding compensation to families affected by fatal road accidents.
