An insured’s false declaration of no prior policies permits repudiation for material non-disclosure.

The petitioner’s deceased father held four Personal Accident Insurance policies issued by New India Assurance Company Limited, each providing cover of ₹25 lakh, effective from 25 September 2023 to 24 September 2024.

On 30 April 2024, he died after falling from a moving train; the police investigation concluded that the death resulted from an accidental fall.

The petitioner notified the insurer and submitted claims. The insurer repudiated the claims on 26 December 2025, alleging non-disclosure of earlier insurance policies.

The proposal forms were electronic and included a field for “Previous Policy Number”; the insured entered “0” rather than leaving it blank or disclosing the earlier policies.

After withdrawing an earlier writ petition, the petitioner brought this petition challenging the repudiation.

Whether the insurer could repudiate the policies on the ground that the insured failed to disclose previous insurance policies, where the electronic proposal forms specifically sought that information and the insured entered “0”.

Whether the authorities relied on by the petitioner concerning blank or unfilled proposal-form fields prevented repudiation in these circumstances.

Insurance contracts require disclosure of material facts relevant to the insurer’s assessment of risk.

Under Reliance Life Insurance Company Limited v. Rekhaben Nareshbhai Rathod, information specifically sought in a proposal form is presumed material; where previous policies are queried, non-disclosure may entitle the insurer to repudiate if the information is material to its decision to accept the risk.

Under Manmohan Nanda v. United India Assurance Company Limited, if a proposal-form column is left blank and the insurer nevertheless accepts the premium and issues the policy without seeking completion, it cannot later rely on that omission to repudiate.

The Court also considered the definition of “proposal form” and “material” information under Regulations 2(d) and 4 of the IRDAI (Protection of Policyholders’ Interests) Regulations, 2002, and the requirements for electronic proposal forms under the IRDAI (Issuance of E-Insurance Policies) Regulations, 2016.

The Court found that the proposal forms expressly asked for previous policy numbers and that the insured entered “0,” rather than leaving the field blank.

Applying Reliance Life, it treated the requested information as material to the insurer’s assessment of risk.

It distinguished Manmohan Nanda and Santosh Kumar v. Assistant Secretary/Deputy Secretary/Secretary, Insurance Ombudsman, Lucknow, because those cases concerned a blank field, whereas here the insured had supplied an answer that did not disclose the earlier policies.

On that basis, the Court found no illegality in the repudiation.

It dismissed WPA No. 1304 of 2026 and granted no relief to the petitioner.