The Supreme Court’s dismissal of the claim in G. Nagarathna v. G. Manjunatha reaffirms the “self-tortfeasor” doctrine, denying compensation under Section 166 of the Motor Vehicles Act to legal heirs when the deceased was solely at fault. However, this outcome highlights a gap in equitable relief—one that could have been bridged through Section 163-A, a no-fault provision that allows compensation regardless of negligence. As MV Tribunal proceedings are summary in nature, courts must balance legal doctrines with the Act’s welfare objectives to ensure justice for dependents left behind.
New Delhi (ABC Live): Self-Tortfeasor Doctrine: On July 2, 2025, the Supreme Court of India dismissed the Special Leave Petition in G. Nagarathna & Ors. vs. G. Manjunatha & Anr., affirming the Karnataka High Court’s view that the legal heirs of a negligent driver cannot seek compensation under Section 166 of the Motor Vehicles Act, 1988.
While this aligns with the doctrine of “self-tortfeasor” laid down in cases like Ningamma v. United India Insurance Co. Ltd., the verdict raises serious questions about access to justice, statutory equity, and alternate legal remedies.
? What Was the Case About?
The petitioners, family members of a man who died in a car crash, filed a claim under Section 166, alleging the accident was caused by a tyre burst. However, both the High Court and the Supreme Court agreed that:
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The deceased was himself driving the vehicle,
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He was charge-sheeted under Sections 279, 337, and 304A IPC, and
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The tyre burst followed, not caused, the accident.
This led to dismissal of the claim under the “self-tortfeasor” doctrine, which bars compensation when the deceased is solely at fault.
?? Equity Lost in Doctrinal Rigidity?
The Motor Vehicles Act, a piece of welfare legislation, aims to provide just and reasonable compensation to victims and dependents. Courts have repeatedly emphasised that MV Tribunal proceedings are summary in nature and governed by the “preponderance of probabilities”, not strict evidence or criminal standards.
Yet here:
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The courts did not explore the tyre burst theory in depth,
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The claim was dismissed based on technical negligence attribution, and
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The dependents were denied compensation, despite being financially and emotionally affected.
? Section 163-A: The Missed Legal Remedy
This case exemplifies why claimants should consider Section 163-A of the MV Act, a no-fault liability provision where negligence need not be proven.
Why it matters:
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No need to prove fault or absence of negligence,
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Fixed compensation based on the Second Schedule, and
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Even if the deceased was at fault, heirs can still claim.
The Supreme Court in United India Insurance Co. Ltd. v. Sunil Kumar (2017) upheld this right, affirming that Section 163-A claims are maintainable even against oneself.
? Legal Takeaways
| Legal Path | Fault Required? | Claim Allowed if Deceased at Fault? |
|---|---|---|
| Section 166 | Yes | ? No |
| Section 163-A | No | ? Yes |
| Section 140 (interim relief) | No | ? Yes |
???? Human Rights Angle: Right to Livelihood
Denying compensation to dependents of deceased drivers solely because of fault raises questions under Article 21 of the Constitution – the right to life and livelihood. Additionally, it challenges Article 39-A, which mandates equal access to justice.
?? Final Word: Balance Law with Compassion
The Supreme Court’s summary dismissal may be legally sound, but it overlooks the broader welfare purpose of the MV Act. Legal heirs should not suffer doubly—from loss of life and loss of compensation—due to rigid application of fault doctrines.
? Recommendation:
Legal heirs should pursue claims under Section 163-A if negligence is disputed or attributed to the deceased, ensuring access to compensation even in no-fault scenarios.
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