Chhattisgarh High Court
Civil Procedure and EvidenceConstitutional Law

Premature withdrawal of compensation deposits requires demonstrated necessity, not unsupported claims of borrowed expenses.

SMT. HIRMOTI SAHU vs DINESH SHUKLA

Chhattisgarh High CourtJUDGMENT: September 25, 20262 MIN READSOURCE JUDGMENT
Premature withdrawal of compensation deposits requires demonstrated necessity, not unsupported claims of borrowed expenses.. SMT. HIRMOTI SAHU vs DINESH SHUKLA. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, claimants under a motor accident compensation award dated 13 December 2025, were awarded ₹8,00,000 and ₹5,00,000 respectively, with directions that ₹4,00,000 and ₹2,50,000 of their respective entitlements be kept in fixed deposits for three years

Source reference: para. 3

They sought premature withdrawal, stating that they needed funds to repay amounts borrowed from relatives and well-wishers for their son’s marriage.

Source reference: no citation

The Tribunal rejected successive applications, noting that the petitioners had not accounted for the ₹6,50,000 already disbursed, established their income or agricultural resources, or provided details of the alleged loans.

Source reference: paras. 3, 5

They challenged the Tribunal’s order dated 27 July 2026 under Article 227 of the Constitution

Source reference: para. 2
02

Issues

Whether the High Court should interfere under Article 227 with the Tribunal’s refusal to permit premature withdrawal of compensation held in fixed deposits

Source reference: paras. 2, 6

Whether the petitioners established sufficient grounds for premature withdrawal by showing a need to repay amounts allegedly borrowed for their son’s marriage

Source reference: paras. 5–6
03

Law Applied

Article 227 of the Constitution was invoked as the basis for supervisory review of the Tribunal’s order

Source reference: para. 2

The Court applied no separately identified statutory test for premature withdrawal; its reasoning turned on whether the petitioners had substantiated their asserted necessity with adequate material.

Source reference: no citation

It considered A.V. Padma & Ors. v. R. Venugopal & Ors., AIR online 2012 SC 530, and Aidal Singh & Anr. v. State of U.P. & Ors., 2024 SCC OnLine All 455, but held them distinguishable on the facts

Source reference: paras. 3, 7
04

Reasoning

The petitioners relied principally on the marriage and the need to repay alleged loans, but produced no supporting documents beyond the marriage card and did not identify the persons from whom they had borrowed or the amounts borrowed

Source reference: paras. 5–6

The Tribunal had also noted the absence of an account of the amount already disbursed and the petitioners’ failure to disclose income from their agricultural land

Source reference: para. 5

In light of these evidentiary gaps, the High Court found no ground to interfere with the Tribunal’s decision under Article 227 and found that the cited precedents did not assist the petitioners

Source reference: paras. 6–7
05

Holding

The Court held that the petitioners had not established a sufficient need for premature withdrawal of the fixed-deposit amounts and declined to interfere with the Tribunal’s order

The writ petition was dismissed

Source reference: para. 8
Chhattisgarh High Court

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SMT. HIRMOTI SAHUvsDINESH SHUKLA

Chhattisgarh High Court · September 25, 2026

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