Source: Supreme Court 

Why in News? 

Recently, the bench of Justices PS Narasimha and R Mahadevan held that the legal heirs of a deceased tortfeasor cannot claim compensation under Section 166 of the Motor Vehicles Act for an accident caused by his own rash and negligent driving. 

• The Supreme Court held this in the matter of G. Nagarathna & Ors. v. G. Manjunatha & Anr. (2025). 

What was the Background of G. Nagarathna & Ors. v. G. Manjunatha & Anr. (2025)? 

• N.S. Ravisha was driving a Fiat Linea car at high speed in a rash and negligent manner when the vehicle toppled, resulting in his death.  
• The deceased was not the owner of the vehicle but had borrowed it from the actual owner.  
• Following the fatal accident, Ravisha's legal heirs, including his wife, son, and parents, filed a compensation claim of ₹80 lakhs under Section 166 of the Motor Vehicles Act, 1988, before the Motor Accident Claims Tribunal (MACT), Arsikere. 
• The appellants sought compensation for the death of their family member despite the fact that the accident occurred due to his own rash and negligent driving.  
• The legal heirs argued that since the deceased was not the owner of the vehicle, the insurance company could not avoid its liability to provide compensation for the loss that occurred.  
• The case involved the fundamental legal question of whether legal heirs can claim compensation under the Motor Vehicles Act when the deceased person was himself responsible for the accident through his own negligent driving, constituting a self-inflicted tort or offence against road safety regulations 

What were the Court’s Observations? 

• The Karnataka High Court observed that the accident occurred due to the rash and negligent driving of the deceased himself, making him a self-tort-feasor, and therefore his legal heirs cannot claim any compensation for his death, as it would amount to a person who committed a breach getting compensation for his own wrongs.  
• The High Court further observed that since the deceased had borrowed the vehicle from the owner, he is deemed to have stepped into the shoes of the owner, and hence the insurance company cannot be held liable to compensate the owner or borrower for injuries or death caused by their own negligence 
• The Court noted that allowing such compensation would set a dangerous precedent where individuals could benefit from their own wrongful acts or offence against traffic regulations.  
• The Supreme Court observed that there was no good ground for interference with the impugned decision of the High Court and reiterated the established legal principle that legal heirs of a deceased person driving a vehicle negligently cannot seek compensation under the Motor Vehicles Act. 

What is Section 166 of the Motor Vehicles Act? 

About: 

• Section 166 of the Motor Vehicles Act provides the legal framework for filing applications seeking compensation arising out of motor vehicle accidents.  
• An application for compensation can be made by the person who has sustained injury in the accident, enabling them to seek redressal for their physical harm and related losses.  
• The owner of property damaged in the accident is also entitled to file an application for compensation under this section to recover losses for property damage. 
• Where death has resulted from the motor vehicle accident, all or any of the legal representatives of the deceased person are empowered to make an application for compensation on behalf of the deceased.  
• Any agent who has been duly authorized by the injured person or by all or any of the legal representatives of the deceased can also file a compensation application on their behalf. 
• The section mandates that where all legal representatives of the deceased have not joined in the compensation application, the application must be made on behalf of or for the benefit of all legal representatives of the deceased, and those legal representatives who have not joined must be impleaded as respondents to the application. 
• Every application under this section must be made at the option of the claimant to either the Claims Tribunal having jurisdiction over the area where the accident occurred, or to the Claims Tribunal within whose local limits the claimant resides or carries on business, or within whose local limits the defendant resides. 
• The application must be in the prescribed form and contain the prescribed particulars as required by the rules.  
• Where no claim for compensation under section 140 is made in the application, the application must contain a separate statement to that effect immediately before the signature of the applicant.  
• The Claims Tribunal is required to treat any report of accidents forwarded to it under sub-section (6) of section 158 as an application for compensation under the Motor Vehicles Act. 

Case Laws: 

• Ningamma and another v. United India Insurance Co. Ltd., (2009): 
  • To establish the legal principle that when an accident occurs due to the rash and negligent driving of the deceased himself, making him a self-tort-feasor his legal heirs cannot claim any compensation for his death.  
  • The Court cited this precedent to support its conclusion that allowing compensation in such circumstances would amount to a person who committed a breach getting compensation for his own wrongs, which would be contrary to established legal principles. 
• Minu B. Mehta v. Balkrishna Nayan, (1977): 
  • The Court applied the legal principle established in this case that when a person borrows a vehicle from the owner, he is deemed to have stepped into the shoes of the owner for the purposes of liability and insurance coverage.