Extending Justice Beyond Life: The Supreme Court’s Compensation Ruling

In a compassionate and constitutionally sound ruling the Supreme Court of India revisited the long-standing legal and human implications of personal injury claims in Meena (Dead) Through LRs v. Prayagraj & Ors. (Civil Appeal @ SLP (C) No.12187 of 2019).

What began as a claim by a grievously injured accident victim ended as a testament to how justice can and must transcend mortality, ensuring that the rights of the deceased are not extinguished but inherited by their legal heirs as part of their estate.

What's The Matter?

The facts were harrowing. Meena, the original claimant, had sustained life-altering injuries in a bus accident in 2005 that left her 100% disabled. After surviving nearly 19 years in a vegetative state, she passed away in January 2024 while the matter was still pending appeal.

The Supreme Court acknowledged the unfortunate timing of her death but emphatically upheld the right of her legal heirs her husband and two daughters to continue the claim.

The Court placed reliance on the 2022 ruling in Oriental Insurance Co. Ltd. v. Kahlon, reaffirming that compensation awarded for injury constitutes part of the deceased’s estate and can be pursued even after their death.

The original compensation awarded by the Motor Accident Claims Tribunal (MACT) and partially enhanced by the High Court amounted to ₹8.56 lakhs, which included loss of income, pain and suffering, medical expenses, and attendant care.

However, the Supreme Court found room for greater equity.

It observed that Plaintiff two-decade-long ordeal warranted higher compensation for future treatment even posthumously and thus increased the amount for that head alone from ₹1 lakh to ₹2 lakhs.

A key point of contention was the assessment of income. Plaintiff was a married woman without formal employment but claimed to earn through stitching and embroidery an assertion dismissed by the Tribunal for lack of evidence.

The Court nevertheless accepted a modest monthly income of ₹3,000 and applied a standard multiplier of 13 with a 10% increase, resulting in a recalculated loss of income at ₹5.14 lakhs.

It is significant that the Court recognized the economic contributions of homemakers and informal workers, even in the absence of documentary proof a progressive shift in valuing women's unpaid and informal labour.

The total enhanced compensation was calculated as ₹12,53,770, including medical bills, pain and suffering, special diet, loss of amenities, future treatment, and attendant charges.

The Court directed the insurance company to deposit the remaining compensation amount, with interest, into individual accounts of the legal heirs within two months underscoring the principle that the wheels of justice must move with both fairness and efficiency.

The judgment stands out for several reasons.

First, it reinforces the evolving jurisprudence that injury claims do not die with the claimant but survive as part of their estate.

Second, it humanises compensation law by acknowledging the prolonged suffering and care needs of victims in vegetative states. And third, it recognises the rights of women, particularly those in unrecognised employment, to equitable redress in personal injury cases.

By upholding the right of family to inherit the fruits of her pending claim, the Supreme Court has sent a clear message: the law will not abandon victims at the intersection of death and justice.

In doing so, it deepens the meaning of compensation transforming it from a mere monetary remedy into a symbol of dignity, even in death.

Disclaimer: This blog is for educational and informational purposes only. It does not constitute legal advice.