Separate claims under Sections 163A and 166 may arise from the same accident.

Smt. Shaila Devi died when the Maruti car in which she was travelling fell into the Bhagirathi River on 12 November 2015.

Her dependants sought compensation under Section 166 of the Motor Vehicles Act, 1988.

The Tribunal found that the driver’s rash and negligent driving caused the accident and awarded ₹5,79,160, assessing the deceased’s monthly income at ₹4,680 by reference to the MGNREGA rate.

The insurer appealed, disputing negligence, the income assessment, and the filing of a Section 166 claim alongside a separate Section 163A claim arising from the same accident, concerning the death of the driver/owner.

Whether the Tribunal’s finding that the accident resulted from the driver’s rash and negligent driving was supported by the evidence.

Whether a Section 166 claim for the passenger’s death was legally barred because a separate Section 163A claim had been filed concerning the driver/owner’s death in the same accident.

Whether the insurer’s challenge to the compensation award warranted interference.

Section 166 of the Motor Vehicles Act, 1988 requires proof of negligence as a condition of establishing the claim; Section 163A provides for compensation on a no-fault basis.

The Court identified no legal bar to separate claims under these different provisions arising from the same accident.

It also applied the principle that the Motor Vehicles Act is beneficial legislation and should, where ambiguity exists, be interpreted liberally in favour of claimants.

The Tribunal’s negligence finding rested on PW2, an eyewitness who testified that the car was being driven swiftly before it went into the river; the High Court found that evidence supported the finding that the driver’s negligence caused the accident.

The earlier Section 163A claim concerned the driver/owner and proceeded on a no-fault basis, whereas the present Section 166 claim required and, in the Court’s view, established negligence.

The earlier claim therefore did not undermine the present finding, and the insurer identified no legal provision barring separate claims under the two sections.

The Court rejected the challenge to the award, including the challenge to quantum.

It directed that the balance amount be remitted to the Tribunal within 45 days and that the statutory deposit in the Registry be remitted forthwith; the original record was also directed to be returned to the Tribunal.