High Courts Can’t Pick and Choose from Precedents: Supreme Court Reiterates Binding Force of Constitution Bench in Motor Accident Compensation

“Article 141 is not optional — deviation from Pranay Sethi is a manifest error of law”, On 06 February 2026, the Supreme Court of India delivered a strong reminder on judicial discipline and the binding nature of precedents while determining compensation under the Motor Vehicles Act, 1988.

A Bench of Justice Dipankar Datta and Justice Satish Chandra Sharma held that High Courts and Tribunals cannot selectively apply or ignore Constitution Bench rulings, particularly in relation to future prospects and conventional heads of compensation. The Court categorically ruled that non-application of Pranay Sethi amounts to a manifest error of law, warranting correction in appeal.

“Structured formula is not advisory, it is binding law”

The appeal arose from a fatal accident claim where the Madras High Court, while partially enhancing compensation, failed to grant future prospects and awarded compensation under ‘loss of love and affection’, despite clear law to the contrary.

The Supreme Court noted that the controversy before it was not about generosity, but about faithful application of binding precedent in a field where uniformity and certainty are indispensable.

“Article 141 leaves no room for discretion in settled fields” - Judicial Discipline and Precedential Hierarchy

The Court emphasised that the principles governing determination of compensation have been authoritatively structured by Constitution Bench decisions, particularly in National Insurance Co. Ltd. v. Pranay Sethi. The Bench observed that once the Constitution Bench has laid down the law, courts of lesser strength are constitutionally bound to follow it without deviation.

The Court held in substance that

“Assessment of income, addition of future prospects, selection of multiplier and grant of conventional heads are no longer matters of unguided discretion.”

Failure to apply the structured formula laid down in Pranay Sethi, the Court ruled, undermines consistency and equality before law, leading to arbitrary variations in compensation awards across jurisdictions.

“Ignoring precedent breeds uncertainty and inequity” - Why Uniformity Matters in Motor Accident Claims

The Supreme Court highlighted that motor accident compensation affects thousands of litigants annually, and inconsistent application of law can lead to similarly placed claimants receiving vastly different awards.

The Bench cautioned that

“If Tribunals and High Courts are permitted to award compensation based on personal notions of fairness, the very concept of ‘just compensation’ would become uncertain and subjective.”

The Court reaffirmed that structured guidelines laid down in Sarla Verma, refined and finalised in Pranay Sethi, exist precisely to prevent such unpredictability.

“Constitution Bench decisions are not to be diluted by sympathy” - Limits of Compassion in Adjudication

While recognising the human tragedy involved in fatal accident cases, the Court clarified that sympathy cannot justify deviation from binding law. Emotional appeal, the Bench held, cannot override constitutional discipline.

The judgment reiterates that beneficial legislation does not mean boundless discretion, and that courts must balance compassion with legal certainty and precedent-based reasoning.

“Correction by Supreme Court is inevitable where discipline fails” - Appellate Intervention Justified

By enhancing compensation and correcting errors committed by the High Court, the Supreme Court made it clear that departure from settled law invites appellate correction. The Bench underscored that such intervention is necessary to preserve coherence in the administration of justice.

The Court’s direction awarding future prospects as mandated and removing ‘loss of love and affection’ as a separate head was not an exercise of generosity, but a constitutional obligation.

The judgment in V. Pathmavathi serves as a clear institutional message: precedents of Constitution Benches are binding commands, not optional guidelines. In motor accident compensation jurisprudence, where uniformity is vital, judicial discipline is the backbone of fairness.

By reiterating the supremacy of Pranay Sethi under Article 141, the Supreme Court has reinforced that consistency, predictability and adherence to precedent are integral to delivering “just compensation” under the Motor Vehicles Act.

Date of Decision: 06 February 2026