No Causal Link Between Injury and Death: Supreme Court Rejects Compensation Claim Where Victim Died Five Months After Accident

Supreme Court upheld a High Court judgment that denied compensation to dependents of a deceased man under the Motor Vehicles Act, ruling that no proximate or direct causal connection existed between the road accident injuries and the eventual death.

The deceased, a government Excise Guard, suffered fractures to his leg and finger in an accident but died five months later of pulmonary embolism and myocardial infarction. While the Motor Accident Claims Tribunal had allowed compensation by linking the death to the accident injuries, the High Court reversed this, and the Supreme Court refused to interfere, citing absence of “preponderance of probability” and “inconclusive expert medical opinion.”

“Functional Injuries Must Be Linked to Fatal Outcome – Possibility Is Not Proof”: SC Applies Preponderance Standard in Civil Claim

A Bench comprising Justice K. Vinod Chandran and Justice N.V. Anjaria emphasized that even under the lower standard of civil proof, a claimant must establish more than a mere possibility that the accident caused the death. The Court noted:

“Merely by reason of the proximity of the accident and the death… it cannot be assumed, without clear evidence, that the death occurred by reason of the accident.”

The Court distinguished between temporal proximity and causation, noting that the deceased had resumed outpatient treatment and underwent a surgical skin graft for a non-healing ulcer five months after the accident, which had involved only fractures and wounds to the leg and finger.

“Doctor’s Own Testimony Points to Natural Causes”: SC Holds Medical Evidence Did Not Support Compensation for Death

The plastic surgeon (PW-1) who treated the deceased admitted during cross-examination that no post-mortem had been conducted and that cardiac risk factors like diabetes, hypertension, and high cholesterol were present.

Though he stated that bed rest might trigger embolism, he acknowledged:

• No post-mortem was done (which could have confirmed embolism conclusively),

• The deceased had preoperative cardiac symptoms, and

• There was no clear record of extended bed rest.

The Supreme Court found that the doctor’s evidence did not support the Tribunal’s finding and was more consistent with the High Court’s conclusion that death likely resulted from natural causes post-surgery, not the accident per se.

“Absence of Post-Mortem and Clear Medical Link Fatal to Claim”: SC Dismisses Appeal for Death Compensation

The Court observed that the lack of post-mortem, refusal by the family, and lack of documented medical advice for extended bed rest all significantly weakened the claim. The Bench reasoned:

“There cannot be found even a preponderance of probability, going by the Doctor’s evidence.”

It added that although the skin graft surgery was successful, the death that followed appeared to be a surgical complication unrelated to the initial accident injuries. As such, the Court refused to disturb the High Court’s reasoned denial of death compensation, while upholding compensation for the injuries alone.

Decision Date: 4 September 2025