Court’s Decision
The Supreme Court dismissed an appeal filed by the mother of a deceased accident victim challenging the disbursement of compensation by the Motor Accident Claims Tribunal (MACT). The Court upheld the orders of the MACT and the Gauhati High Court, holding that once the appellant had consciously signed the joint petition, accepted ₹1,00,000 by cheque, and encashed it without protest, she could not later question the distribution.
The Bench observed:
“The appellant, having accepted the cheque voluntarily and signed the order sheet, acted with open eyes and cannot now approbate and reprobate.”
Facts
The case arose from the death of Priyank Chand in a road accident on 27 February 2009, when a truck collided with the Indica car he was travelling in. His mother (the appellant), widow (respondent no. 1), and two minor children (respondent nos. 2 and 3) filed MACT Case No. 125 of 2009 seeking compensation.
On 11 November 2011, the Tribunal awarded ₹11,82,000 to the claimants. The insurance company’s appeal against the award was dismissed by the Gauhati High Court on 9 September 2014.
On 21 April 2015, pursuant to a joint application by the claimants, the Tribunal disbursed the compensation as follows:
- ₹1,00,000 to the mother (appellant),
- ₹6,26,000 with interest to the widow, and
- ₹3,00,000 each in fixed deposits for the minor children.
The appellant signed the joint petition and the order sheet, received her cheque of ₹1,00,000, and encashed it. However, in 2016, she filed a review petition alleging unfair apportionment and claiming her rights as a Class I legal heir under succession law. The review was dismissed for a delay of 6 months and 22 days. The Gauhati High Court upheld this dismissal on 22 January 2021. The appellant then approached the Supreme Court.
Issues
- Whether the Tribunal’s apportionment of compensation among legal heirs was contrary to succession law.
- Whether the appellant could challenge the disbursement after voluntarily accepting her share without protest.
- Whether the delay of over six months in filing the review petition was sufficiently explained.
Petitioner’s Arguments
The appellant argued that the apportionment order of 21 April 2015 was unjust and contrary to succession law, as she was a Class I heir entitled to an equal share with the widow and children. She claimed that she was prevented from properly participating in the proceedings and alleged that her son was tactically prevented from entering the court when the disbursement was pronounced.
She explained the delay in filing the review petition by citing medical issues, including surgery between May and December 2015. She contended that the Tribunal and High Court erred in not condoning this delay.
Respondent’s Arguments
The widow argued that the appellant was present in court during the disbursement, signed the joint petition and order sheet, and voluntarily accepted the cheque. By encashing the cheque without objection, she waived her right to later challenge the distribution.
It was further contended that the review petition was an afterthought, filed only after the appellant became dissatisfied with the amount received. The medical grounds for delay were unsubstantiated, as no documents were produced.
Analysis of the Law
The Supreme Court reiterated settled principles:
- Doctrine of approbate and reprobate: A person cannot accept benefits of an order and later challenge it.
- Delay in review: Courts can condone delay only if sufficient cause is shown. Mere dissatisfaction with the outcome does not justify late challenges.
- Succession law vs. joint petitions: While succession law grants equal rights to Class I heirs, voluntary settlement through joint petitions binds the parties, especially if acted upon.
The Court noted that the appellant signed the joint petition, accepted the cheque, and encashed it, which amounted to conscious acceptance of the order.
Precedent Analysis
- Doctrine of approbate and reprobate – Applied here to hold that acceptance of benefits bars subsequent challenge.
- Principles of natural justice – The Court noted no violation, as the appellant participated in proceedings and signed documents.
- Delay jurisprudence – Consistent with rulings that unexplained or inadequately explained delay cannot be condoned.
Court’s Reasoning
The Court held that the appellant could not establish any fraud in the Tribunal’s disbursement order. Her conduct showed conscious participation:
- She signed the joint application with her daughter-in-law.
- She signed the Tribunal’s order sheet acknowledging receipt.
- She accepted and encashed the cheque of ₹1,00,000 without protest.
The plea of medical illness was unsupported by documents. Dissatisfaction with the share received was not a valid ground to re-open concluded proceedings.
Thus, the Tribunal and High Court were correct in dismissing the review petition and revision application.
Conclusion
The Supreme Court dismissed the appeal, affirming that once a claimant voluntarily accepts and encashes compensation, they cannot later challenge the apportionment. The appellant’s conduct, delay, and lack of evidence precluded relief.
Implications
This ruling underscores that compensation claimants must raise objections at the appropriate stage. Once benefits are accepted without protest, courts will not permit reopening of disbursement orders. It reinforces the finality of settlements in motor accident claims and discourages belated litigation driven by dissatisfaction.
FAQs
1. Can a claimant reopen a motor accident compensation order after accepting payment?
No. Acceptance and encashment without protest bar later challenges under the doctrine of approbate and reprobate.
2. Does being a Class I heir guarantee equal share in motor accident compensation?
Not necessarily. If parties file a joint application for disbursement and accept payment, they are bound by that arrangement.
3. Can delay in filing a review petition be excused on medical grounds?
Only if substantiated by evidence. Unsupported claims of illness or surgery will not justify condonation of delay.
