Insurer of Tractor Liable for Accidents Involving Uninsured Attached Trailer as Root Cause of Incident

On July 1, 2021, the deceased, a laborer, was traveling on a trailer attached to a tractor to unload iron rods. The tractor was driven negligently, causing the vehicle to turn turtle, resulting in the deceased’s death.

The 3rd Motor Accident Claims Tribunal (Aux.) at Dhari awarded Rs. 7,14,000/- with 7.5% interest to the claimants.

The appellant Insurance Company challenged this award, contending it was not liable because while the tractor was insured with them, the attached trailer was uninsured.

1. Whether the Insurance Company can be exonerated from liability to pay compensation when the accident involves an insured tractor pulling an uninsured trailer.

The Motor Vehicles Act, 1988, which is recognized as beneficial and welfare-oriented legislation.

If the tractor is the "root cause" of the accident while pulling a trailer, the insurer of the tractor remains liable even if the trailer is not separately insured as per Royal Sundaram Alliance Insurance Co. Ltd. v. Smt. Honamma & Ors. (2025 INSC 625).

Following the Honamma ratio, the Court reasoned that the tractor was the "main cause" and the "root cause" of the accident, as it was the prime mover that caused the trailer to upturn during the course of being driven.

Justice Mool Chand Tyagi noted that technicalities regarding separate registration/insurance of a trailer should not overshadow the reality that the insured tractor propelled the chain of events leading to the injury.

Since the deceased was a laborer (not a gratuitous passenger) and the tractor was the active agent of the accident, the chain of liability was established.

The appeal was dismissed, and the Insurance Company was ordered to satisfy the award.

The Court directed the Tribunal to disburse the entire awarded amount to the claimants after due verification.