Victim died about 5 months after accident, SC upholds HC’s rejection of compensation claim for death of Excise Guard

The Supreme Court on September 4, 2025 upheld a High Court order that overturned the award of the Motor Accident Claims Tribunal which had held that the death of an Excise Guard nearly five months after an accident was directly linked to injuries sustained in the mishap. A bench of Justices K Vinod Chandran and N V Anjaria said that without clear medical evidence establishing causation, the death could not be treated as a consequence of the accident and compensation on that count was not maintainable.

The case arose from an accident on April 29, 2006 in which the victim, an Excise Guard, suffered fractures of the second, third and fourth metatarsals of his right foot and a simple fracture of the proximal phalanx of the left little finger. He was admitted as an inpatient until May 3, 2006 and was later treated as an outpatient until August 12, 2006. The injuries also resulted in a wound at the fracture site. His condition required continued medical attention and he was eventually referred to a higher medical centre for plastic surgery consultation when a non-healing ulcer developed on the right foot.

On September 18, 2006, almost five months after the accident, he was admitted to the higher centre. Doctors performed a skin grafting procedure which was reported as successful. However, the victim died abruptly on the same day of pulmonary embolism and acute myocardial infarction. The Tribunal held that the death was the result of the accident and granted compensation on that basis. The High Court later set aside this finding, holding that the link between the accident and the death was not established, though compensation for the injuries was allowed.

In appeal, the wife, minor child and mother of the deceased argued that the fractures, wound and subsequent grafting procedure led to the complications culminating in death. They relied on the sequence of treatment and the continuous medical history from the accident to the date of death. The claimants stressed that the accident had triggered the health complications and that but for the mishap the victim would not have undergone the surgery after which he died.

The Supreme Court examined the medical evidence in detail. It noted that the plastic surgeon who performed the procedure had testified that the death could not be directly linked to the accident. The judges said the medical evidence did not show even a preponderance of probability that the injuries sustained led to the death. They observed that the non-healing ulcer could have been caused by several factors, especially given the victim’s diabetic condition. The surgery was performed to address the ulcer and the grafting was successful, but the death that followed could have been the result of post-surgical complications or the patient’s underlying medical profile rather than the accident itself.

The bench recorded that the Tribunal’s conclusion that death flowed directly from the accident was not sustainable in the face of expert opinion. The High Court had correctly evaluated the evidence and found no nexus between the accident injuries and the cause of death. The Supreme Court said the High Court’s reasoning was well-considered and warranted no interference. The claim for death compensation was therefore rejected, while the recognition of injury compensation remained.

The Court emphasized that mere proximity of time between an accident and a later death cannot automatically justify a conclusion of causation. It held that the possibility of acute myocardial infarction occurring due to long bed rest or complications could not be treated as proof of accident-related death in the absence of reliable medical evidence. The bench noted that the statement of the deceased’s wife regarding his health condition contradicted the testimony of the doctor who had been examined on behalf of the claimants themselves. The death occurred in a hospital after a medical procedure and there was no evidence to show that the accident injuries directly led to pulmonary embolism or myocardial infarction.

Case Title: Haseena & Ors Vs The United India Insurance Co Ltd & Anr

Judgment Date: September 4, 2025

Bench: Justices K Vinod Chandran and N V Anjaria