Madhya Pradesh High Court Broadens Definition of Legal Representatives Under Motor Vehicles Act

High Court Rules Unmarried Cohabitants Entitled to Compensation as Legal Representatives

In a landmark judgment, the Madhya Pradesh High Court has expanded the interpretation of "legal representatives" under the Motor Vehicles Act, 1988, allowing individuals who can prove financial dependency on the deceased to claim compensation, even if they are not legal heirs under personal laws.

The case, Smt. Saroj v. Rajendra Prasad Patel, arose from a tragic accident on December 8, 2010, when Ramakant Patel died after being hit by a Bolero Jeep driven recklessly by one of the respondents. Though the deceased was unmarried, he had been living with appellant No.1, the widow of his brother, in a relationship recognized by their community. The Tribunal initially awarded compensation to the deceased's father, rejecting the claims of the appellants who lived with the deceased and were financially dependent on him.

Appealing this decision, the appellants argued their dependency was overlooked due to the marital status of appellant No.1, despite evidence of their cohabitation and mutual dependency. The High Court, presided over by Justice Himanshu Joshi, overturned the Tribunal's decision, emphasizing that under the Motor Vehicles Act, the term "legal representative" should be interpreted broadly to include individuals who demonstrate financial dependency, not just those who are legal heirs.

Citing the Supreme Court's stance in N. Jayasree v. Cholamandalam MS General Insurance Co. Ltd., Justice Joshi reinforced that the Act is intended to provide monetary relief to families of accident victims, necessitating a liberal interpretation of "legal representatives." The Court recognized that a cohabitant in a stable, long-term relationship with the deceased, akin to marriage, should be eligible for compensation.

The judgment sets a precedent for acknowledging relationships beyond conventional marital ties in compensation claims, underscoring the Act's benevolent intent. The case has been remanded back to the Tribunal to reconsider the appellants' claims, with directions to award compensation afresh, treating them as legal representatives of the deceased.

The High Court's decision marks a significant step towards ensuring substantive justice, reflecting evolving societal norms and recognizing diverse familial structures. The Tribunal is expected to expedite the process, delivering a fresh award within three months.

Bottom Line:

Motor Vehicles Act, 1988 - Legal representative under the Act includes individuals who can prove financial dependency on the deceased, and is not restricted to legal heirs as per personal laws.

Statutory provision(s): Motor Vehicles Act, 1988 Section 173(1)

Smt. Saroj v. Rajendra Prasad Patel, (Madhya Pradesh)(Jabalpur) : Law Finder Doc Id # 2794850