Punjab & Haryana High Court Enhances Compensation for Minor’s Death to ₹5 Lakh Under Amended Motor Vehicles Act; Applies Beneficial Section 164 Retrospectively
Case Name: Neeraj Saini & Another v. National Insurance Company Ltd. & Another
Date of Judgment: October 31, 2025
Citation: FAO-3817-2025
Bench: Hon’ble Mrs. Justice Sudeepti Sharma
Held: The Punjab & Haryana High Court enhanced the compensation payable to the parents of a 17-year-old accident victim from ₹2.28 lakh to ₹5 lakh, holding that the benefit of Section 164 of the Motor Vehicles Act, 1988—as amended by Act 32 of 2019—applies retrospectively to pending cases under Section 163-A. Justice Sudeepti Sharma ruled that the Motor Vehicles Act is a beneficial legislation, and procedural technicalities should not obstruct substantive justice to victims or their dependents.
Summary: The claimants—parents of deceased Diksha Saini, aged 17—had been awarded ₹2.28 lakh with 7.5% interest by the Motor Accident Claims Tribunal, Pathankot, under Section 163-A for her death in a 2014 accident. On appeal, they contended that the compensation should be recalculated in line with Section 164 (introduced in 2022), which fixes ₹5 lakh for death and ₹2.5 lakh for grievous injury on a no-fault basis.
The Court accepted the plea, relying on Ram Murti v. Punjab State Electricity Board [2022 (4) TAC 738] and its own earlier ruling in Akaljit Kaur v. Parveen Kumar (FAO-4301-2006), where similar retrospective application of Section 164 had been recognized. It reiterated that technical distinctions between statutory provisions should not defeat the humanitarian object of compensation statutes. Justice Sharma emphasized that the judiciary must interpret welfare legislation empathetically, ensuring that procedural lapses do not deny substantive justice.
Decision: The appeal was allowed. The compensation was enhanced by ₹2.72 lakh (₹5,00,000 − ₹2,28,000) with interest at 9% per annum from the date of claim filing until realization. The insurer was directed to deposit the enhanced amount within two months, to be disbursed in equal shares to both appellants through the Tribunal.