Stray Animal Accident Victims Can Pursue Civil Compensation Through Civil Suit; 2025 Policy Not Sole Remedy: Punjab & Haryana High Court
Case Name: Punjab State & Another v. Sukhmandar Singh (Deceased) through Legal Representatives & Another
Date of Judgment: 04.05.2026
Citation: RSA-1706-2026
Bench: Hon’ble Mr. Justice Parmod Goyal
Held: The Punjab & Haryana High Court held that legal representatives of a victim who died after colliding with stray animals on a public road are entitled to seek compensation through a civil suit, and the Punjab Compensation to the Victims of Animal Attacks and Accidents Policy, 2025 does not bar such a remedy. The Court further held that policies introduced after the accident cannot retrospectively deprive claimants of their civil rights, though they may serve as guiding factors in determining compensation.
Summary: The State of Punjab challenged the concurrent judgments of the Trial Court and the First Appellate Court directing payment of ₹20 lakh as compensation to the parents of Lakhwinder Singh, who lost his life after his motorcycle collided with a group of stray animals on a National Highway near village Bathlan on 07.10.2019.
The plaintiffs had instituted a civil suit seeking compensation from the State of Punjab and the Municipal Council, Dhanaula, contending that the accident occurred due to the authorities’ failure to control stray animals on public roads. The Trial Court decreed the suit and awarded compensation of ₹20 lakh. While the First Appellate Court absolved the Municipal Council of liability for want of evidence showing that the accident occurred within municipal limits, it upheld the State’s liability.
Before the High Court, the State sought to rely upon the Punjab Compensation to the Victims of Animal Attacks and Accidents Policies of 2023 and 2025, arguing that compensation could only be granted through the committee constituted under those policies and that a civil suit was not maintainable.
Rejecting the contention, the High Court observed that the accident had occurred in 2019, whereas the compensation policies were framed subsequently in 2023 and 2025. Consequently, the policies could not retrospectively extinguish or restrict an accrued civil cause of action.
The Court held that although the 2025 Policy may act as a guiding factor while assessing compensation in older cases, it cannot be treated as the exclusive remedy available to victims or their legal representatives. It further noted that the policy itself contemplates compensation on principles similar to those applicable under the Motor Vehicles Act, 1988.
The Court also found no infirmity in the concurrent factual findings of the courts below. The testimony of the eyewitness, the death certificate and other corroborative evidence sufficiently established that the deceased died due to a collision with stray animals. Applying the civil standard of proof based on preponderance of probabilities, the Court held that the claim stood duly proved.
Considering the age and income of the deceased, the High Court concluded that the award of ₹20 lakh could not be regarded as excessive and declined to interfere with the concurrent findings.
Decision: The High Court dismissed the State’s Regular Second Appeal and upheld the award of ₹20 lakh compensation in favour of the deceased’s legal representatives. It also affirmed the First Appellate Court’s finding absolving the Municipal Council of liability, holding that there was no evidence establishing that the place of occurrence fell within municipal limits.