The Punjab & Haryana High Court has clarified that statutory amendments providing higher compensation under the Motor Vehicles Act must be applied retroactively to pending claims, ensuring that victims’ families benefit from legislative intent to provide just and adequate relief. This ruling reinforces the principle that remedial statutes are to be interpreted liberally in favor of claimants.
Background & Facts
The Dispute
The appellants, legal heirs of Jile Singh @ Jila, sought enhanced compensation after their family member died in a motor vehicle accident on 11.09.2025. The Motor Accident Claims Tribunal, Karnal, awarded Rs. 2,89,500 under Section 163-A of the Motor Vehicles Act, 1988, which was in force at the time of the accident. However, by the time the appeal was heard, Section 164 of the Motor Vehicles Act, 1988 (as amended by Act 32 of 2019, effective 01.04.2022) had replaced Section 163-A, providing for a fixed compensation of Rs. 5 lakhs in cases of death.
Procedural History
- 11.09.2025: Motor accident resulting in death of Jile Singh @ Jila, aged 41
- 04.03.2010: Tribunal awarded Rs. 2,89,500 under pre-amendment Section 163-A
- 2022: Section 164 came into force, replacing Section 163-A with higher fixed compensation
- 2026: Appeal filed before Punjab & Haryana High Court seeking enhancement under Section 164
Relief Sought
The appellants sought enhancement of compensation to Rs. 5 lakhs under Section 164, along with interest from the date of filing the claim petition, and argued that the amended provision, being beneficial, must apply to pending cases.
The Legal Issue
The central question was whether Section 164 of the Motor Vehicles Act, 1988 (as amended in 2019) applies retroactively to claims filed under the repealed Section 163-A, where the accident occurred before the amendment but the adjudication was pending.
Arguments Presented
For the Appellant
The appellants relied on Ram Murti and others v. Punjab State Electricity Board and the High Court’s own decision in Akaljit Kaur v. Parveen Kumar, arguing that the Motor Vehicles Act is a beneficial legislation meant to provide swift and adequate relief. They contended that the substitution of Section 163-A with Section 164 was not merely procedural but substantive and favorable, and therefore, under the doctrine of beneficial construction, the higher compensation must be granted to pending claimants. They emphasized that denying the benefit would defeat the legislative intent behind the amendment.
For the Respondent
The insurance company argued that the claim was filed and adjudicated under Section 163-A, and the accident occurred before the amendment. They contended that applying Section 164 retrospectively would violate the principle of non-retroactivity of statutes and create uncertainty in settled claims. They further argued that the Tribunal had correctly applied the law as it stood at the time of the accident.
The Court's Analysis
The Court examined the nature of the Motor Vehicles Act as a social welfare statute designed to provide speedy and adequate compensation to victims of road accidents. It noted that the amendment replacing Section 163-A with Section 164 was not merely procedural but substantially enhanced the quantum of compensation, reflecting Parliament’s intent to improve victim relief.
"The Motor Vehicle statute is a beneficial legislation, and the Judge should not go into the technicalities of the provisions, under which the application or petition is moved but should apply his judicial mind, as these are only the irregularities and not illegalities which cannot be cured."
The Court distinguished between substantive and procedural changes, holding that where a statute introduces a more favorable remedy for claimants, and the case is pending adjudication, the benefit must be extended. It affirmed that the Supreme Court in Ram Murti had already recognized this principle, and the High Court’s prior decision in Akaljit Kaur had applied it consistently. The Court rejected the argument that the amendment could not apply retroactively, noting that the claim had not been finally decided at the time of the amendment’s enforcement. It further emphasized that judicial empathy and public trust in the system demand that beneficiaries of such legislation not be deprived of enhanced statutory benefits due to procedural delays.
The Verdict
The appellants won. The Court held that Section 164 of the Motor Vehicles Act, 1988 applies to pending claims even if the accident occurred before its enforcement. The compensation was enhanced to Rs. 5 lakhs, with interest at 9% per annum from the date of filing the claim petition, and the insurance company was directed to deposit the amount within two months.
What This Means For Similar Cases
Beneficial Amendments Apply to Pending Claims
- Practitioners must now argue that any statutory amendment increasing compensation under the Motor Vehicles Act must be applied to claims pending adjudication, regardless of the accident date
- This principle extends beyond Section 164 to any future amendments that enhance victim relief
- Opposing counsel cannot rely on the date of accident to deny benefits under newer, more favorable provisions
Judicial Empathy Overrides Technical Formalities
- Courts are directed to prioritize substantive justice over procedural technicalities in motor accident claims
- Arguments based on strict temporal application of repealed sections will be rejected if the new provision is beneficial
- Judges must exercise discretion with empathy, as emphasized in Akaljit Kaur, to uphold public confidence in the judicial system
Interest and Payment Timelines Are Now Standard
- Interest at 9% per annum from the date of filing is now mandatory on enhanced compensation, per Dara Singh and R. Valli
- Insurance companies must deposit enhanced amounts within two months and disburse scheduled fees to advocates within 20 days of judgment receipt
- Failure to comply may invite contempt proceedings or enforcement under Section 25 of the MV Act
