Supreme Court ruled a tree-fall incident was not a motor accident under the Motor Vehicles Act.

The Supreme Court has held that a tree falling on an autorickshaw would not entitle an injured passenger to seek compensation under the Motor Vehicles Act (MVA).

A Bench of Justices Sanjay Karol and N Kotiswar Singh said that in such a situation, the motor vehicle itself does not play an active role in the accident and is not part of its proximate cause. Therefore, a claim under Section 166 of the Motor Vehicles Act would not be maintainable.

However, adopting what it described as a humane approach in line with constitutional principles, Court directed payment of ₹25 lakh as compensation to K K Umesh Kumar, who suffered serious injuries in the incident.

How Did the Accident Occur?

Kumar was travelling in an autorickshaw on June 23, 2007, from Queens Road to Chinnaswamy Stadium in Bengaluru. Due to heavy rain, he requested the driver to stop the vehicle by the roadside.

The autorickshaw was parked beneath an old tree when a branch suddenly detached and fell on the vehicle, causing serious injuries to Kumar. The area had several old trees, some of them nearly a hundred years old.

What Happened Before the Supreme Court?

On April 10, 2013, the Motor Accidents Claims Tribunal, Bengaluru, dismissed Kumar's claim for ₹50 lakh compensation, holding that the incident was a result of a natural calamity.

The Karnataka High Court later allowed his appeal and awarded compensation of ₹17,10,500. It directed that 25% of the amount be paid by the Bruhat Bengaluru Mahanagara Palike (BBMP), 50% by the autorickshaw's insurer, and the remaining 25% by the Horticulture Department of the Karnataka Government.

Challenging this decision, the BBMP and the Horticulture Department argued that they could not be held responsible for the unfortunate incident.

Why Did the Supreme Court Reject Liability Under the Motor Vehicles Act?

Court observed that neither taking shelter under a tree during heavy rain nor parking the autorickshaw beneath it was anything out of the ordinary. It also noted that the falling of the branch could not reasonably have been anticipated by the authorities or the autorickshaw driver.

"In these circumstances, it would be unfair to fasten the liability upon the appellant under the MVA," the Bench said.

Court further explained that while municipal authorities have a duty to maintain trees and ensure public safety, it would be unrealistic to expect them to keep constant watch over every tree in an expanding city.

"It is a reality that the boundaries of City are ever expanding in India, in view of the constant migration, and so the number of people that a Corporation is serving increases over time. It would be unrealistic to expect that authorities of the Corporation can maintain a constant vigil over each tree/shrub," Court observed.

The Bench added that although old branches may sometimes give way, the solution cannot be to indiscriminately cut all branches from old trees.

Would the Position Be Different if the Victim Was Not in a Vehicle?

Addressing the central issue, Court noted that if a pedestrian standing beneath the same tree to take shelter from the rain had been injured by the falling branch, the incident would have been essentially the same.

Court observed that the presence of the autorickshaw in such circumstances was merely incidental and that the vehicle itself was not the cause of the accident. For that reason, the claim could not properly be treated as one arising out of the use of a motor vehicle under the Motor Vehicles Act.

Why Did the Court Still Award ₹25 Lakh Compensation?

Despite holding that liability could not be imposed under the Motor Vehicles Act, Court emphasised that a person who has suffered life-altering injuries should not be left without any financial support.

"A person who has suffered such life altering grievous injuries, being left in lurch, without any money to sustain himself, does not appeal to the conscience of justice," the Bench said.

Court added that, as the country's highest court, it was obligated to ensure that the law is implemented in a humane manner consistent with constitutional values.

Finding that the compensation awarded by the high court was inadequate and based on an overly technical approach, Court enhanced the amount to ₹25 lakh along with interest from the date of filing of the claim petition.

Exercising its powers under Article 142 of the Constitution, Court left the high court's apportionment of liability undisturbed and directed that the compensation be disbursed within four weeks.

Case Title: Commissioner, Bruhat Bangalore Mahanagara Palike Vs K K Umesh Kumar & Ors

Bench: Justices Sanjay Karol and N Kotiswar Singh 

Date of Judgment: June 11, 2026

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