Mere Involvement of a Vehicle in Chain of Events Leading to Death Cannot Trigger Motor Accident Compensation Without Causal Nexus; Death Must ‘Arise Out of’ Use of Motor Vehicle: Supreme Court
Case Name: Dilip Agarwal v. Rajshri Agarwal & Ors.
Date of Judgment: 22 July 2026
Citation: 2026 INSC 736
Bench: Justice Sanjay Karol and Justice Augustine George Masih
Held: The Supreme Court held that liability under the Motor Vehicles Act cannot arise merely because a motor vehicle happens to form part of the chain of circumstances preceding a person’s death. The expression “arising out of the use of a motor vehicle” requires a causal link between the use of the vehicle and the injury or death, though the connection need not be as direct as that contemplated by the expression “caused by”. While a murder may, in appropriate circumstances, amount to an “accidental murder” where the killing occurs in furtherance of some other felonious act connected with the vehicle, no such nexus was established in the present case. Even applying the civil standard of preponderance of probabilities, there was no evidence demonstrating that the deceased sustained the fatal injuries in or because of the appellant’s car.
Summary: The deceased, Anand, left in a car driven by his friend Dilip Agarwal on 29 November 2009 and was found dead three days later. His wife and children filed a claim under Section 166 of the Motor Vehicles Act alleging that he had been killed inside Dilip’s vehicle. The Motor Accident Claims Tribunal awarded ₹5.64 lakh with interest, and the High Court affirmed liability while enhancing the compensation to ₹8,60,832. Separately, Dilip had been convicted for offences including murder but was subsequently acquitted by the High Court because the prosecution failed to establish the “last seen” theory.
The Supreme Court clarified that the standard of proof in a motor accident claim is preponderance of probabilities, unlike proof beyond reasonable doubt in criminal proceedings. Therefore, an acquittal in the criminal case would not by itself defeat a compensation claim. Nevertheless, the lower civil standard does not dispense with the requirement of proving facts connecting the vehicle with the death.
On examining the evidence, the Court found no forensic material such as blood, skin cells or hair recovered from the car and no allegation that the vehicle had been involved in a collision. The courts below had effectively assumed that the deceased suffered the fatal injuries while inside the car without evidentiary foundation. The Supreme Court stressed that although claimants are not required to prove the exact manner in which injuries occurred, “some link whatsoever” between the vehicle and the death must still be established.
The Court distinguished cases where a murder may constitute an accident for Motor Vehicles Act purposes, explaining that where the dominant intention is another felonious act and death occurs incidentally in furtherance thereof, compensation may be attracted. In the present case, however, neither such a primary-secondary felony relationship nor any causal connection with the use of the vehicle was proved.
Decision: The Supreme Court allowed the appeals and set aside the judgments of the Tribunal and the High Court, holding that no liability could be imposed under the Motor Vehicles Act because the necessary causal relationship between the motor vehicle and Anand’s death had not been established. However, considering the peculiar facts, the Court directed that any compensation already paid to the claimants shall not be recovered from them.