The Punjab & Haryana High Court has clarified that funds deposited in a fixed deposit account for a minor victim of a motor accident must be released in full upon the minor attaining majority. The judgment rejects arbitrary partial disbursements and affirms the beneficiary’s absolute right to access compensation awarded by the Motor Accident Claims Tribunal once legal adulthood is achieved.
Background & Facts
The Dispute
The petitioner, Sumer Kumar, was a minor at the time of a motor vehicle accident that resulted in serious injury. The Motor Accident Claims Tribunal, Karnal, awarded him compensation, which was directed to be deposited in a Fixed Deposit Account (FDR A/c No. 946408) with Canara Bank, Assandh, to be held until he attained the age of majority or for a period of five years, whichever was later.
Key Facts
- The accident occurred prior to the filing of the claim petition, resulting in a compensation award by the MACT.
- The Tribunal ordered the entire compensation amount to be deposited in FDR with Canara Bank, Assandh, for the petitioner’s benefit.
- The petitioner attained the age of majority on or before 08.04.2026, the date of the High Court’s judgment.
- On 16.01.2026, the MACT, Karnal, passed an order allowing only Rs. 1,00,000/- to be released from the FDR, without providing any reasoned justification.
- The petitioner submitted Annexure P-4, an agreement to sell a property, demonstrating urgent need for the full amount to complete the purchase.
- The petitioner had no other source of funds to meet this legitimate financial obligation.
Procedural History
- Date of Accident: Not specified in judgment, but claim filed while petitioner was a minor.
- Date of MACT Award: Not specified, but deposit ordered pending majority.
- 16.01.2026: MACT, Karnal, ordered release of only Rs. 1,00,000/- from FDR.
- 28.03.2026: Petitioner filed revision petition before the Punjab & Haryana High Court.
- 08.04.2026: High Court heard arguments and delivered judgment.
Relief Sought
The petitioner sought modification of the MACT’s order dated 16.01.2026 to direct the release of the entire amount deposited in FDR A/c No. 946408 with Canara Bank, Assandh, along with accrued interest, for immediate use in purchasing property.
The Legal Issue
The central question was whether a Motor Accident Claims Tribunal may restrict the release of compensation funds deposited in FDR for a minor, upon the minor attaining majority, without any compelling reason or statutory basis.
Arguments Presented
For the Petitioner
Learned counsel argued that once the petitioner attained majority, he became the absolute legal owner of the compensation award. The deposit was a protective mechanism during minority, not a perpetual trust. The MACT’s refusal to release the full amount, without any evidence of misuse or risk, was arbitrary and violated the petitioner’s fundamental right to property and personal autonomy. The submission of the property purchase agreement demonstrated a legitimate, urgent need.
For the Respondent
The Insurance Company, represented by Mr. Abhimanyu Kalsy, did not oppose the petition and expressed no objection to the release of the entire amount.
The Court's Analysis
The Court observed that the purpose of depositing compensation in an FDR was solely to safeguard the minor’s interest until he attained legal capacity to manage his affairs. Once majority was achieved, the protective rationale ceased to exist. The Tribunal’s order of 16.01.2026, which released only Rs. 1,00,000/-, was devoid of any reasoning, statutory authority, or factual justification.
"The Tribunal failed to appreciate that the petitioner has now attained the age of majority and is entitled to the full benefit of the award granted in his favour."
The Court emphasized that compensation under the Motor Vehicles Act is not a grant or welfare benefit, but a legal right arising from tortious liability. The beneficiary, upon attaining majority, is entitled to full and unimpeded access to the award. The Tribunal’s partial release amounted to an unauthorized restriction on the petitioner’s property rights, unsupported by law.
The Court further noted that the petitioner had demonstrated a concrete and urgent need for the funds through the annexed property agreement, reinforcing the legitimacy of his request.
The Verdict
The revision petition was allowed. The order dated 16.01.2026 of the Motor Accident Claims Tribunal, Karnal, was set aside. The Bank Manager of Canara Bank, Assandh, is directed to release the entire amount lying in FDR A/c No. 946408, along with accrued interest, in favour of the petitioner within one week from the date of judgment. All pending applications are disposed of.
What This Means For Similar Cases
Full Access Upon Majority Is Absolute
- Practitioners representing minor accident victims must file applications for release of FDR funds immediately upon the beneficiary turning 18.
- Tribunals cannot impose arbitrary caps or require additional justification beyond proof of majority.
- Any partial release without reasoning is liable to be set aside on revision.
Documentation of Need Is Advisable
- While not legally mandatory, submitting evidence of legitimate use (e.g., property agreements, medical bills, education fees) strengthens the application and preempts tribunal hesitation.
- Courts will favor release when the use is lawful and urgent.
No Continuing Tribunal Oversight After Majority
- Once majority is attained, the Tribunal loses jurisdiction to control or restrict the use of compensation funds.
- The beneficiary becomes the sole legal owner; no guardian or tribunal approval is required for withdrawal.
