Veerapaneni Venkata Subhashini & Anr. v. Arikatla Venkata Rathnam & Anr., 2026

The deceased was employed as a tractor driver and died in 2012 after the tractor overturned during the course of employment.

The deceased's widow and minor son filed a claim petition seeking compensation under Section 163-A of the Motor Vehicles Act, 1988.

They asserted that the deceased was employed by the first respondent and earned ₹10,000 per month.

The Motor Accidents Claims Tribunal (MACT) held that the accident occurred due to the deceased's own negligence.

The Tribunal further observed that there was no documentary evidence proving the deceased's employment or salary.

Consequently, the Tribunal restricted compensation to ₹50,000 under Section 140 of the Motor Vehicles Act.

Aggrieved by the award, the claimants preferred an appeal before the Andhra Pradesh High Court seeking enhancement of compensation.

The insurer also failed to produce evidence showing that the deceased did not possess a valid driving licence.

The Andhra Pradesh High Court allowed the appeal and set aside the Tribunal's findings restricting compensation.

The Court held that Section 163-A is a beneficial welfare provision under which proof of negligence is irrelevant.

It observed that even if the deceased himself was negligent, his legal heirs are not disentitled from claiming compensation under Section 163-A.

The Court held that the Tribunal erred in rejecting the widow's unrebutted oral testimony regarding the deceased's employment merely because documentary proof of salary was unavailable.

It observed that in the agricultural sector, wages are frequently paid through informal arrangements, making documentary proof difficult.

The Court further noted that the insurer failed to establish that the deceased did not possess a valid driving licence.

Considering the beneficial object of the Motor Vehicles Act, the Court held that the claimants were entitled to the enhanced statutory compensation of ₹5,00,000 under Section 164, introduced by the Motor Vehicles (Amendment) Act, 2019.

The Court awarded ₹5,00,000 as compensation together with 9% interest per annum from the date of filing of the claim petition until realization.

The judgment reinforces that Section 163-A embodies the principle of No-Fault Liability, under which establishing negligence is unnecessary.

It reiterates that the Motor Vehicles Act is a beneficial and social welfare legislation intended to provide speedy and effective compensation to victims and their families.

The Court adopted a liberal interpretation to ensure just and reasonable compensation in line with the welfare objective of the Act.

The judgment recognizes the practical realities of employment in the agricultural sector, where wages are often paid without formal documentation.

The Court clarified that the absence of documentary salary records cannot automatically discredit otherwise reliable oral evidence.

By extending the benefit of Section 164 despite the accident preceding the 2019 Amendment, the Court emphasized the importance of awarding maximum statutory benefit during final adjudication.

The decision strengthens the rights of dependents of deceased drivers by ensuring that compensation is not denied merely because the deceased contributed to the accident.

The judgment is likely to serve as an important precedent in cases involving No-Fault Liability, Motor Accident Compensation, and Beneficial Interpretation of welfare statutes.