During the British regime, Indian Motor Vehicle Act of 1914 was ratified with an
objective to regulate enforcement and to ensure the registration and licensing
of vehicles and motorists to maintain road safety. This was replaced by 1939 Act
which consolidated and amended the law relating to motor vehicles according to
the development in road transport technology, pattern of passenger and freight
movements and particularly the improved techniques in the motor vehicles
management, this was later further substituted by MV Act, 1988. The 1988 Act was
a significant law which established a new court named Motor Accidents Claims
Tribunals which replaced civil courts in order to provide cheaper and speedier
relief to the victims of accident of motor vehicles.
Earlier, the suit claiming
compensation needed to be filed in civil court along with an ad- valorem court
fee. Since, the civil courts had a backlog of cases to adjudicate, the person
expecting damages was not able to receive the compensation in time and due to
the court fee, the victim was further discouraged to not file for compensation.
This was remedied in 1988 Act where a separate court for motor accident claims
was formed and without paying any ad- valorem court fee. In this act, licensing
of the motorists and registration of the vehicle mandatory.
Further, it made it
mandatory to obtain a Learner's license for all the drivers wanting to get a
license and it was made obligatory to use the L
board and the company of an
instructor while driving in a public place. It also proposed that any person
under the age of 20 is not allowed to drive a vehicle in a public place and a
learner's license or driving license should only be issued if he or she is
This act was further substituted by Motor Vehicle (Amendment) Act of
2019 whose aim was to ensure road safety and stricter rules. The notable
features of this Act encompass damages up to two lakhs for road accident victims
and hefty fines for wilful offenders. The bill also mentions a recall of those
vehicles which entail undue safety risks to other motorists, the driver, and the
environment. With the amendment of the bill, the Central government created the
National Road Safety Board as an advisory board to manage and regulate road
safety and traffic.
What is Claims Tribunal?
Established by Motor Vehicle Act 1988, Claims Tribunal is defined under Chapter
XII in Section 165 which authorises the State Government to constitute Claims
Tribunals to adjudicate on the claims for compensation which emerge from motor
vehicle accidents, ensuing death or bodily injury to persons or damage to any
property of third parties. Its objective is to provide remedy to the victims of
accident by motor vehicles in appropriate time without any procrastination.
Motor Accident Claims Tribunals [MACT Courts] handle those claims which are in
relation to loss of life/property or those injury cases arising out of Motor
These Claims need to be directly filed in the respective Tribunal. MACT Courts are administered by Judicial Officers from Delhi Higher Judicial
Service. Currently these Courts are under immediate supervision of the High
Courts of various States. Under Section 165 (2) the number of members to be
assigned in Claims Tribunal is more than/equal to two, one of them is to
nominated as the Chairman and under Section 165 (3), the eligibility for the
appointment of members is that the member should be a Judge of a High Court or
District Judge or ought to be eligible for appointment as a Judge of a High
Court or District Judge.
Claim for Compensation under Motor Vehicle Act
Who can claim compensation?
Section 166 of MV Act 1988 illustrates who can plead for compensation in MACT in
a motor accident case. A person who has himself sustained injury or he owns the
property or he is the legal representative of the deceased who died in the motor
accident or he is the agent authorized by the injured person, or by the legal
representatives of the deceased, as the case maybe- can claim compensation.
When can compensation be claimed?
The limitation period i.e., the time period during which the claim for
compensation can be realised is six months from the occurrence of the accident.
This time period has been fixed under the 2019 Amendment Act. It means that
after the expiration of six months, application claiming damages cannot be
claimed. It is further illustrated that if the victim claims compensation
according to the procedures formed under Section 164 provided under Section 149,
the application for compensation filed before the Claims Tribunal shall be
Where can the application for compensation be filed?
It is at the option of the claimant to file an application for compensation. The
application can be filed either at the Claims Tribunal of the area where the
accident occurred or at the Claims Tribunal of the area where the claimant
resides/ carries business or at the Claims Tribunal of the area where the
Relevant Case Laws
Powers and Procedures of Claims Tribunal
- National Insurance Company Limited vs Pranay Sethi and Ors: A
Constitutional Bench of the Apex Court held that the Multiplier concept and
deduction in personal and living expenses as laid down in the Sarla Verma case.
However, the future aspects in awarding damages under Section 166 of the Motor
Vehicles Act have been newly formulated by following the standardization
principle. The principles that have been laid down are the factors to be
figured, the deceased's income, age and the number of his/her dependants.
- Nagappa v. Gurudayal & Ors.: The Supreme Court held that the claimant
filing an application for damages under Section 166, does not restrict the
Claims Tribunal in awarding more compensation than that was claimed if the
Tribunal is certain that awarding more compensation is just and appropriate and
neither peremptory, whimsical nor unwarrantable from the evidence.
- New India Assurance Company Limited vs. Sadanand Mukhi and Others:
Supreme Court held that no damages will be provided under Section 163-A or
Section 166 as here the victim was the owner's son who was driving the vehicle
in which the accident happened and the victim died and hence, he was not
regarded as third party becoming ineligible for compensation.
Under Section 169, the Claims Tribunal has the power to formulate and establish
its own procedure. It possesses all the powers of the Civil Court in the case of
taking evidence on oath, of effectuating the attendance of witnesses and of
mandating the discovery and production of documents and material objects and for
such other purposes as may be specified.
It shall be considered a Civil Court
for all the objectives to be fulfilled under section 195 and Chapter XXVI of the
Code of Criminal Procedure, 1973. The importance of this tribunal is that it
ensures speedier adjudication of compensation suits without shaping it into
elaborate and long-drawn proceedings and hence, preventing undue delay in
Claims Tribunal has the liberty to nominate one or more
persons who are equipped with certain special knowledge about any issue that is
related with inquiry of the compensation claims. With the 2019 Act, for
successful execution of Tribunal's decision on any compensation claim, it is authorised to execute a decree under the Code of Civil Procedure, 1908 which is
similar to that of Civil Court.
Under Section 175, the civil courts do not have
the authority to entertain any question related to compensation claims in areas
where Claims Tribunal has been constituted and is not answerable to the Civil
Court for any action or decision made by the Tribunal and also it does not have
the authority to direct in any manner to the Tribunal with regard to any issues
of compensation claims.
Relevant Case Laws
Authority of State Governments to form rules
- National Insurance Company Ltd. Vs Lachhibai Urf Laxmibai and Others:
In this case, MP High Court held that a review application is maintainable when
it is sought due to a procedural defect, or unintended error effectuated by the
Tribunal, to prevent misuse of its process. The argument of the learned counsel
for the non-applicant cannot be accepted that power of review is not given under
the statute, hence, it cannot review its own order. Wide powers are intrusted
with the Tribunal under Section 169 of the Motor Vehicles Act. Thus, review on
limited grounds is permissible.
- Kailash Chandra Sharma vs E. Gurunath and Ors: In this case, the MP
High Court held that though under Section 169, the Claims Tribunal has broad
range of powers similar to that of Civil Court for all the objectives of Section
195 and Chapter XXVI of the Code of Criminal Procedure, 1973 but such powers
ought to be carried out by the Tribunal for providing justice to the party.
Hence, the court set aside the direction issued by the Tribunal under which the
claimant was mandated to pocket the expenses of the opponents including the
Insurance Company and also held that opponents shall pay their own expenses and
if they succeed in proving themselves innocent then it can be claimed from the
Section 176 of MVA, 2019 empowers the state government to form rules or
regulations with the objective of providing smooth functioning of sections 165
to 174 like determining the particulars that a form of application should
contain and how the fees, if there is any, to be paid with regard to such
applications; what should be the procedures to be pursued by the Claims Tribunal
while holding any investigation; ascertaining the powers of Civil Court which
may be employed by the Claims Tribunal in adjudication of compensation claim;
deduction of the basis and the manner in which an appeal contesting the award
of the Tribunal and the fees for the same, etc., is to be done.
Relevant Case Laws
- Lata vs United India Insurance Co. Ltd.: The Himachal Pradesh High
Court held that Section 176 (d) of the Act clearly empowers the State Government
to formulate rules relating to the form and the manner in which an appeal may be
opted against an award of a Claims Tribunal. The expressions 'form' and 'manner'
are wide enough to encompass a possible stipulation about the relevancy of the
provisions of Order 41, Rules 22 and 33 of the Civil Procedure Code to appeals
made under Section 173 of the Act. In accordance of this power, the State
Government did construct Rules called "Himachal Pradesh Motor Vehicles Rules,
In Chapter XII of MVA 2019, Section 173 illustrates the provision of appeals
against the award of Claims Tribunal.
In which court, the appeal contesting the award of Claims Tribunal shall be
Under Section 173 (1), any person who is dissatisfied with the decision of the
Claims Tribunal can file an appeal to the High Court.
What is its limitation period?
Section 173 (1) stipulates that an appeal can be filed against the award of
Claims Tribunal must be done within ninety days from the date of the decision.
It is further specified that failure to file an appeal within the said time
period can be excused only on the ground that the appellant was unable to do so
in time due to sufficient cause.
How much amount must be deposited before the appeal can be considered by the
The High Court must consider the appeal only if the person has deposited with it
either twenty-five thousand rupees or fifty per cent. of the amount so awarded,
according to the procedure established by the High Court.
On which awards of the Claims Tribunal, an appeal contesting the same cannot be
Section 173 (2), added with the 2019 Act stipulates that no appeal against the
award of Claims Tribunal shall be valid if the amount of dispute in the appeal
is less than one lakh rupees.
Relevant Case Laws
Prosecution of insurer in particular cases
- S. Venkata Subbaiah vs Kodavali Chinnappa and Ors.: In this case, the
Andhra Pradesh High Court held that since the owner of the vehicle/appellant
failed to adhere to the first proviso to Section 173(1) i.e., did not submit Rs.
25000 or half of the award amount, the appeal is not maintainable.
- Devidas v. Chandrakala and Ors.: The Bombay High Court held that the
court can decline to register the appeal under Section 173(1) if the deposit is
not made within the stipulated period.
- Sohan Singh v. Kushla Devi and Ors.: The Punjab and Haryana High Court
held that under Section 173(1) any person who is mandated to pay any amount as
decided by the Claims Tribunal, prefers an appeal, the said appeal can be
considered by the High Court only if the specific amount as required by the said
proviso has been deposited and no claim of exemption to make the deposit can be
admissible on the ground that a co-respondent before the Tribunal has filed an
appeal and has made the requisite deposit. But the High Court would not order
the apportionment of the whole amount deposited by different parties under the
- Anil Saraf v. Namboodas and Ors.: The Madhya Pradesh High Court while
considering the first proviso to Section 173(1) of the M. V. Act held an appeal
under Section 173 of the Act would be considered when the mandatory
pre-requisite i.e., the requisite amount has been deposited by the appellant and
such deposit ought to be made before the appeal is 'entertained'.
Under Section 170, if during the inquiry of a compensation claim, the Claims
Tribunal is assured that both the parties (i.e., the person who is claiming and
the person against whom such claim is made) have a secret agreement or have
colluded for an illegal or dishonest objective, or the opposite party has failed
to challenge the claim filed against him, the Tribunal has the power to initiate
proceedings against the insurer as a party to proceeding i.e., the insurer is
going to be centrally involved in the case.
But in this scenario, the insurer
has the right to challenge the claim on any or all of the grounds mentioned
under Section 150 (2) in which an insurer does not have any liability to pay any
sum decided by the Tribunal unless the insurer had been given notice through the
court before the starting of proceedings in which the Tribunal had decided the
award and hence, the insurer has the right to defend himself/ herself from the
Relevant Case Laws
Determination of Compensatory Costs in particular cases
- National Insurance Corporation Company Limited, Chandigarh v. Nicolletta
Rohtagi and Ors. Reported: The Supreme Court held that where conditions
precedent embodied in Section 170 is satisfied and award is averse to the
interest of the insurer, the insurer has a right to file an appeal challenging
the amount of compensation or negligence or contributory negligence of the
erring vehicle even if the insurer has not filed any such appeal.
- Shankarayya And Anr. vs United India Insurance Co. Ltd.: The Supreme
Court concluded that when the Insurance Company is prosecuted as a party by the
Court under Section 170, it can be permitted to contest the proceedings on
merits only if the conditions antecedent mentioned in the section are found to
be appropriate and for that motive, the Insurance Company has to acquire a
reasoned order in writing from the Tribunal. If this is not obeyed, the
Insurance Company cannot have a broad defence on merits than what is available
to it by way of statutory defence.
- The Oriental Insurance Co. Ltd. vs Smt. Bini Bala Mondal & Ors.: In
this case, the Calcutta High Court refused to approve of the appellant insurer's
submission with respect to section 173 of the 1988 Act. The court found no
inconsistency between the provisions of section 170 and section 173 of the 1988
Act. The provisions of section 173 will have to be read in the context
of section 170 and section 149(2) of the said Act. The expression "any person
aggrieved" will include the insurer within the ambit as indicated in section
149(2) and section 170 of the said Act. Any other interpretation will give rise
to inconsistencies and incongruities. Following the precedent set in Shankarayya's case, the court held that without obtaining leave from the
Tribunal under section 170 of the 1988 Act, an appeal on the merits of the award
of the Claims Tribunal would not be maintainable at the instance of the insurer.
Section 172 stipulates the determination of compensatory costs in certain
Under what circumstances can the Claims Tribunal award compensatory costs?
The Claims Tribunal under Section 172 (1), can direct the insurer or any party
in a compensation claim to pay special costs as compensation if it is certain
that either the compensation claim is invalid as the policy of insurance was
obtained through any kind of fraud or misrepresentation or that any party or
insurer has proposed a false or abrasive claim or defence during the proceedings
of the case. These special costs must be compensated to the insurer or the party
against whom such claim or defence had been advanced.
What is the maximum penalty the Claims Tribunal can award as compensatory costs?
Under Section 172 (2), the Claims Tribunal while awarding the compensatory costs
under sub-section (1) cannot exceed these costs beyond one- thousand rupees.
Can the person paying the compensatory costs be exempted against any other
liability for the misrepresentation or claim or defence as illustrated in
Section 172 (1)?
Under Section 172 (3), the person who is responsible to pay the compensatory
costs cannot escape criminal liability for the misrepresentation or claim or
defence as illustrated in Section 172 (1).
Are the compensatory costs taken into account in any ensuing suit for damages
with respect to such mis-representation, claim or defence?
Under Section 172 (4), the compensatory costs will be taken into account in any
ensuing suit for damages with respect to such mis-representation, claim or
Award of interest where any claim is permitted
Is the Tribunal authorised to award interest along with the amount of
compensation claim in a particular suit?
Under Section 171, the Claims Tribunal may direct the opposite party or parties
to pay simple interest over and above the amount of compensation claim at a
particular rate and from a particular date which must not be before the date of
forming the claim as it may prescribe in this behalf.
Relevant Case Laws:
Award of the Claims Tribunal
What are the procedures the Claims Tribunal follows after it has received the
receipt for compensation claim?
- Rajesh Kumar Vs. Sudhir Rana: The learned Single Judge of the Himachal Pradesh High Court while interpretating Section 171 of the Motor
Vehicles Act, 1988, he observed that Claims Tribunal has the responsibility to
consider question of payment of interest. If the party has not unduly delayed
the proceedings, then it must not be denied interest and if the Tribunal decides
to do so, it should give reasons for the same.
- Raj Kumar and another Vs. Kashmir Singh and others: The Court
observed that that the grant of interest on the awarded amount has been provided
under section 171 of the Motor Vehicles Act, 1988, though the word 'may' and not
'shall' is given in section 171 of the Motor Vehicles Act, 1988, still the
Tribunal while exercising its jurisdiction, may award interest on the quantum of
compensation. In fact, the Claims Tribunal gives interest from the date of
filing of the petition and if the said interest is not given, the Tribunal has
to give proper justification for not doing so.
- Ayush Kumar Bilala vs. Himmat Singh: In the said matter, the Tribunal
had not awarded any interest and no reasons were recorded by the Tribunal for
the same. The Rajasthan High Court held that the Tribunal was not justified in
disallowing the interest without any justification and hence, permitted the
interest at the rate of 9% per year from the date of registering the claim
petition till payment is made.
- Sarvat Kochak V. National Insurance Co. Ltd.: The Jammu & Kashmir
High Court held that the interest takes care of the period between date of claim
and date of payment. If the tribunal deduces that the claimant does not have the
right of interest, proper justifications need to be given, failure to which, the
tribunal would fail to exercise its jurisdiction properly.
- Ramesh Chandra v. Randhir Singh: The Apex Court was deliberating upon
the question, 'whether interest could be awarded even when the same has not been
claimed.' While answering the question in the affirmative, the Hon'ble Supreme
Court held that addition of interest to the compensation, by judicial
discretion, is consecutive in the eyes of law and there is no need to
specifically ask interest in the claim petition. The Apex Court further held
that, the amount of interest is independent of any pleading in that regard and
in any contingent situation it can be even orally asked.
Under Section 168 (1), after receiving the receipt for compensation claim under
section 166, the Claims Tribunal sends notice to the insurer, then both the
parties i.e., the claimant and the insurer are given a chance to prove their
stand on the claim and the Tribunal then, holds an investigation into that claim
After holding the inquiry if the Tribunal finds any validity in the
claim, it may decide an award establishing the quantum of compensation to be
paid by the insurer or owner or driver of the vehicle who was involved in the
accident or by all with respect to the claim which ever seems to be just and the
person/ persons eligible for the award is also adjudicated by the Tribunal.
What are the other formalities fulfilled by the Tribunal after the award has
Under sub- section (2), the Tribunal has the responsibility to provide copies of
the award to the parties concerned as soon as possible and should be delivered
within a period of fifteen days from the date of the award.
What is the maximum period in which the compensation decided by the award has to
be fully paid?
Under sub- section (3), the person responsible to pay the compensation must
within thirty days from the date of declaration of the award by the Claims
Tribunal, deposit the full amount awarded in such manner as the Claims Tribunal
Relevant Case Laws
Preference regarding claims for compensation in particular cases
What is the other option under which the compensation can be claimed in the
scenario of fatality or bodily affliction to any person?
- Kuldeep Singh Bawa v. Tika Ram: The court held that Section 168 of the
Motor Vehicles Act stipulates that the learned Tribunal must conduct an
investigation into the claim petition. Section 169 of the Motor Vehicles Act
illustrates that the learned Tribunal is ought to follow such summary procedure
as it perceives to be appropriate to conduct such an investigation. The
investigation stipulated in Section 168 of the Motor Vehicles Act is distinct
from the civil trial. Section 168 of the Motor Vehicles Act casts a duty on the
learned Tribunal to conduct an inquiry appropriately. The motive of the
legislature behind making this provision is that the victims of road accident
are not left behind.
- General Manager, Kerala State Road Transport Corporation, Trivandrum v.
Susamma Thomas (Mrs.) and Ors.: Justice M.N. Venkatachaliah of Supreme Court
held that the adjudicating of the amount must answer what contemporary society
"would deem to be a fair sum such as would allow the wrongdoer to hold up his
head among his neighbours and say with their approval that he has done the fair
thing". The amount awarded under Section 168 of the Motor Vehicles Act must not
be parsimonious since the "law values life and limb in a free society in
generous scales?" Having said that, a misplaced sympathy, generosity and
benevolence cannot be the major factor for determining the compensation. The
object of providing compensation is to place the claimant(s), to the extent
possible, in almost the same financial position, as they were in, before the
accident and not to make a fortune out of misfortune that has befallen them.
Under Section 167, the person who has endured affliction or has died during the
accident by a motor vehicle, the person/ his legal representatives relying upon
the situation can claim damages under either Workmen's Compensation Act, 1923 or
Motor Vehicle Act, 2019 but not under both.
Relevant Case Laws
Recovery of money from insurer as arrear of land revenue
How does the Claims Tribunal execute the award in case the person responsible to
pay the amount (as decided in the award) fails to pay it?
- Insurance Company Limited vs. Dyamavva & Ors: In this case, the
claimant was compensated by his company under workman compensation Act, 1923.
After this, the claimant also raised a claim under section 166 of Motor vehicles
act 1988 but the Motor Accident Tribunal ordered a deduction of compensation
amount paid by his employer from this compensation amount stating that no one
can ask for damages under both the acts (Section 167).
- Raja and another Vs. Ajay and another: In this case, the court held
that even if the claim under Workman Compensation was held not permissible, the
claimant is not barred to claim remuneration under section 167 of Motor Vehicle
Under Section 174, if the person who is responsible to pay the amount, failed to
pay the whole sum, the Claims Tribunal has the power to put out a certificate
for the amount to the Collector and the Collector may proceed to retrieve the
same in the same manner as an arrear of land revenue.
Relevant Case Laws
- Hirabhai Nanubhai Desai vs State of Gujarat and Ors.: In this case,
the Gujarat High Court held that word 'may' in Section 174 provides an
alternative or an option available to the claimants to ask for issuance of the
certificate for enforcement by the Collector who in his turn then proceeds to
retrieve the same in the same manner as an arrears of land revenue.
- Premilaben Ishwarlal Raijada vs Oriental Insurance Co. Ltd.: In this
case, the Gujarat High Court observed that the Tribunal in this case had rightly
expounded the provisions of Section 110-E of the old Act or Section 174 of the
current Act. The Tribunal has also found that the jurisdiction of the civil
Court is interdicted in such cases and that when the Tribunal failed to
prescribe the amount and to decide as to what was the contributory negligence of
either party to accident caused by the vehicle, the question of operation
of Section 174 would emerge. Dispensation of responsibility between the parties
is merely the function of the Tribunal and the retrieval of the amount paid in
excess of its liability by one opposite party from another party is itself not
an issue of regaining the redundant amount due under the award.
- Narender Singh Kadian vs Dhanpati and Ors.: In this case, the Punjab
High Court observed that when the State Government constructed a rule which
provides for implementation of the award by the Court itself without recourse to
retrieve the same as an arrear of land revenue, it cannot be said that the State
Government acted beyond its power. The rule made by the State Government
granting the power of Civil Court under Order 21, C.P.C. on the Claims Tribunal
cannot be said to be invalid. It is only an addition to Section 174 of the Motor
The creation of Motor Accidents Claims Tribunals through Motor Vehicle Act, 1988
was a watershed in the history of Motor Vehicle Acts which not only provided an
efficient mechanism to resolve claims of motor accident and a speedier and
cheaper remedy to the victims of accident of motor vehicles but also
acknowledged that cases dealing with motor accidents are not similar to other
civil suits filed ordinarily in civil courts and therefore these cases deserve a
separate forum to adjudicate them.
With 2019 Act, the powers and efficiency of
Claims Tribunal have been strengthened by amending, adding and repealing certain
provisions according to the needs of present times like Section 173(2), in which
the appeals contesting the award of Claims Tribunal with amount less than one lakh rupees shall not lie, the amount
'one lakh rupees' has been substituted for
'ten thousand rupees.'
The reason is that since 1988 Act, the average amount in
disputes in Claims Tribunal has significantly increased which made it imperative
to recognise this change in various stipulations of Motor Vehicle Act. Thus,
Claims Tribunal has provided a platform to the victim and the victim's legal
representatives to claim remuneration for the loss incurred in motor accidents
resulting in severe damage to either the person or vehicle or resulted in the
death of a person/ persons.
- The Motor Vehicles Act, 1988, No. 59, Acts of Parliament, 1998 (India).
- Aaditya Kapoor, Brief Analysis of Motor Vehicle Act, 1988, Lex Peeps
from: https://lexpeeps.in/brief-analysis-of-motor-vehicles-act-1988/ [Accessed
July 10, 2021]
- Evolution of Motor Vehicle Policies in India, Chola MS General Insurance
from: https://www.cholainsurance.com/knowledge-center/car-insurance/evolution-of-motor-vehicle-policies-in-india [Accessed
July 10, 2021]
- Mohd Aqib Aslam, The Motor Vehicles Act, 1988. Analysis, Legal Service
India [Online] Available
from: http://www.legalserviceindia.com/legal/article-2663-the-motor-vehicles-act-1988-an-analysis.html [Accessed
July 11, 2021]
- LawTeacher. November 2013. Provisions of Motor Vehicles Act. [online].
[Accessed 20 July 2021].
- Spiti Sarkar, Legal Pronouncements for Compensation under Section 166 of
the Motor Vehicle Act, 1988, Legal Service India [Online] Available
from: http://www.legalserviceindia.com/legal/article-95-legal-pronouncements-for-compensation-under-section-166-of-the-motor-vehicles-act-1988.html [Accessed
15 July 2021]
- Diganth Raj Sehgal, Road Accident Claim Compensation, Ipleaders, July 31,
2019 [Online] Available
from: https://blog.ipleaders.in/road-accident-claim-compensation/#Section_166_of_the_Motor_Vehicles_Act_1988 [Accessed
July 12 2021]
- National Insurance Company Limited vs Pranay Sethi and Ors, 2017 (4) KLT 662
- Nagappa v. Gurudayal & Ors., (2003) 2 SCC 274
- New India Assurance Company Limited vs. Sadanand Mukhi and Others, (2009) 2
- National Insurance Company Ltd. Vs Lachhibai Urf Laxmibai and Others, AIR
1997 MP 172
- Kailash Chandra Sharma vs E. Gurunath and Ors., AIR 2007 MP 161
- Lata vs United India Insurance Co. Ltd., 2005 ACJ 857
- S. Venkata Subbaiah vs Kodavali Chinnappa and Ors., 2003 ACJ 308
- Devidas v. Chandrakala and Ors., 1996(1) ACJ 566
- Sohan Singh v. Kushla Devi and Ors., 1988(1) ACJ 472
- Anil Saraf v. Namboodas and Ors., 1997 ACJ 1411
- National Insurance Corporation Company Limited, Chandigarh v. Nicolletta
Rohtagi and Ors. Reported, (2002) 7 SCC 456
- Shankarayya And Anr. vs United India Insurance Co. Ltd., 1998 ACJ 513
- The Oriental Insurance Co. Ltd. vs Smt. Bini Bala Mondal & Ors., 2001 ACJ
- Supra note 12
- Rajesh Kumar Vs. Sudhir Rana, 2009 ACJ 735
- Raj Kumar and another Vs. Kashmir Singh and others, 2009 ACJ 745
- Ayush Kumar Bilala vs. Himmat Singh, 2007 ACJ 462
- Sarvat Kochak V. National Insurance Co. Ltd., 2006 ACJ 2101
- Ramesh Chandra v. Randhir Singh, 1990 ACJ 777 (SC)
- General Manager, Kerala State Road Transport Corporation, Trivandrum v.
Susamma Thomas (Mrs.) and Ors., 1994 AIR 1631
- Insurance Company Limited vs. Dyamavva & Ors, 2013(2) ALL MR 399 (S.C.)
- Raja and another Vs. Ajay and another, 2007 (2) ACCD 1008 (MP)
- Hirabhai Nanubhai Desai vs State of Gujarat and Ors., (1990) 2 GLR 1265
- Premilaben Ishwarlal Raijada vs Oriental Insurance Co. Ltd., 1998 ACJ 1339
- Narender Singh Kadian vs Dhanpati and Ors., 2000 ACJ 51