Anjani Banafar vs Chandrshekahr on 5 August, 2026

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    Chattisgarh High Court

    Anjani Banafar vs Chandrshekahr on 5 August, 2026

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                          CGHC010007572024
                                                                                                          NAFR
    PAWAN
    KUMAR
    Digitally signed by
                                      HIGH COURT OF CHHATTISGARH AT BILASPUR
    PAWAN KUMAR
    Date: 2026.08.05
    
                                                         Reserved on 24.04.2026
    17:29:18 +0530
    
    
    
    
                                                         Pronouncement on 05.08.2026
                                                         Order (Full) Uploaded on 05.08.2026
    
                                                            MAC No. 86 of 2024
    
                          1 - Anjani Banafar W/o Late Pradeep Banafar Aged About 47 Years R/o Ward No., 19, Ram
                          Mandir Ward, Bazar Para, Bemetara, Post, Tahsil And Distt- Bemetara, Cg
                          2 - Devendra Banafar S/o Late Pradeep Banafar Aged About 29 Years R/o Ward No., 19,
                          Ram Mandir Ward, Bazar Para, Bemetara, Post, Tahsil And Distt- Bemetara, Cg
                          3 - Aditi Banafar D/o Pradeep Banafar Aged About 23 Years R/o Ward No., 19, Ram Mandir
                          Ward, Bazar Para, Bemetara, Post, Tahsil And Distt- Bemetara, Cg
                                                                                                    ... Appellant(s)
                                                                    versus
                          1 - Chandrshekahr S/o Mahesh Ram Navrange Aged About 27 Years Occupation- Driver,
                          R/o Village- Indouri, Police Chouki Dashrangpur, Distt- Kabirdham, Cg, Presently R/o Near
                          Durga Mandir, Milavat Para, Zone-3, Sector-11, Bhilai, Police Station- Khursipar, Distt-
                          Durg, Cg- 490011 Mob- 88713780881 (Driver Of Truck No. Cg- 07- Na- 8111)
                          2 - Rajesh Sharma S/o Laxminarayan Sharma Aged About 50 Years R/o New Khursipar
                          Baba Sweets, Police Station- Khuripar, Bhilai, Distt- Durg, Cg,- 490011 Mob-9826430271
                          (Owner Of Truck No. Cg- 07- Na- 8111)
                          3 - The Branch Manager Oriental Insurance Company Ltd. Zonal Office Bhilai, Shivnath
                          Complex, G.E. Road, Supela, Bhilai, Distt- Durg, Cg- 490023 Mob- 07884035006
                          (Insurance Company Of Truck No. Cg- 07- Na- 8111, Policy No. 192190/31/2023/51,
                          Insurance Code- 131085938 Date From 13-05-2022 To 12-05-2023)
                                                                                                 ... Respondent(s)

    For Appellant(s) : Mr. Amit Kumar Sahu, Advocate
    For Respondent Nos. 1 : Mr. Shikhar Shukla, Advocate
    &2
    For Respondent No. 3 : Mr. R. N. Pusty and Mr. Akash Shrivastava, Advocate

    Hon’ble Shri Justice Sachin Singh Rajput
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    SPONSORED

    C A V Judgment

    This appeal has been filed under Section 173 of the Motor Vehicles

    Act, 1988 (for short MV Act) challenging the award dated 08.12.2023passed

    in Motor Accident Claim Case No. 89 of 2023 by the 1 st Additional Motor

    Accident Claim Tribunal, Bemetara District Bemetara, CG. By the

    impugned award, against a claim of Rs. 1,02,01,784/-, the learned Tribunal

    has awarded compensation of Rs. 19,90,952/- on account of death of

    deceased Lokesh Banafar in an accident that took place on 18.01.2023 by

    rash and negligent driving of the offending vehicle (Truck) bearing

    registration No. CG 07 NA 8111 driven by the respondent No. 1 / driver,

    owned by respondent No. 2 / owner and insured with respondent No. 3 /

    insurance company.

    2. As per the pleadings of the claim application, the deceased was aged

    about 25 years and was earning Rs. 27,166/- per month by working as

    Assistant Grade- III in Municipality Bemetara (AG-3). The appellants /

    claimants were dependent upon the income of the deceased therefore, the

    above stated compensation was claimed.

    3. The respondent Nos. 1 & 2 filed their written statement and denied

    the averments of the claim application and pleaded that on the date of

    accident, the offending vehicle was insured with the respondent No. 3 /

    insurance company there is no violation of terms and conditions of the

    insurance policy, the respondent No. 3 is liable to pay the compensation.

    4. The respondent No. 3 filed his written statement and denied the

    averments of the claim application and pleaded that the compensation

    claimed is excessive and exaggerated. It is specifically denied that the

    deceased was employed as Assistant Grade-III in the Municipality,

    Bemetara and was earning Rs. 27,166/- per month. It is further pleaded

    that the registration of a criminal case against respondent No. 1 at Police

    Station Amanaka, District Raipur, does not establish his negligence. The
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    respondent No. 3 also pleaded that the driver of vehicle No.

    CG/07/NA/8111 was required to possess a valid and effective driving

    licence and that the vehicle must have had a valid permit and fitness

    certificate on the date of the accident. In the event of breach of the policy

    conditions, respondent No. 3 would not be liable to indemnify or pay

    compensation.

    5. The learned Tribunal framed issues on the basis of the pleadings and

    decided the same in favour of the appellants / claimants.

    6. Learned counsel for the appellants / claimants submits that the

    income of the deceased has been taken on the lower side and compensation

    on all other heads is also on the lower side. In support of above contention,

    reliance has been placed on the decisions of the Hon’ble Supreme Court in

    the matters of Smt. Sarla Verma and others VS. Delhi Transport

    Corporation and another reported in (2009) 6 SCC 121 and National

    Insurance Co. Ltd. Vs. Pranay Sethi reported in (2017) 16 SCC 680. He

    further submits that the learned Tribunal erred in deducting 50% amount

    of compensation for contributing negligence. This finding deserves to be set

    aside.

    7. Learned counsel for the respondents supports the award and submits

    that the Tribunal has rightly assessed the monthly income of the deceased

    on the basis of evidence available on record and therefore, awarded just

    compensation which does not require any interference by this Court.

    8. I have heard learned counsel for the parties, considered their rival

    submissions and perused the record.

    9. Firstly, this Court would deal with the submissions advanced by

    learned counsel for the appellants/claimants as to whether the finding

    recorded by the learned Claims Tribunal on the issue of contributory

    negligence can withstand judicial scrutiny. As per the pleadings in the

    claim application the deceased along with his friend Vikrant Singh was
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    returning from Raipur to Bemetara on motorcycle bearing registration No.

    CG 07 H 1073 as a pillion rider. It is pleaded that on the date of the

    accident, the driver of the offending vehicle drove the vehicle in a rash and

    negligent manner and dashed against the motorcycle, resulting in the death

    of the deceased. The learned Claims Tribunal framed issue No. 1 with

    regard to the rash and negligent driving of the offending vehicle whereas the

    issue No. 4(C) with regard to contributory negligence. While issue No. 1 was

    held to be proved whereas the issue No. 4(C) was also answered in the

    affirmative. The burden of proving issue No. 1 lay upon the

    appellants/claimants, whereas the burden of proving issue No. 4(C) relating

    to contributory negligence rested upon the respondents / driver, owner and

    the insurance company.

    10. Smt. Anjani Banafar (AW-1) and Vinit Kumar Singh (AW-2) was

    examined on behalf of the appellants / claimants. Both of them are not eye

    witnesses that they have not stated anything. However, AW-1 has stated

    that his son died in the accident by rash and negligence of the offending

    vehicle. She has exhibited the true copy of the criminal paper of Crime No.

    37 of 2023 registered at Police Station Aamanaka District Raipur, CG total

    26 pages as Ex. P-1. From the perusal fo the criminal papers, it appears

    that the FIR was lodged against the driver of the offending vehicle. After

    completion of investigation a charge-sheet under Sections 279, 337, 338

    and 304-A of IPC was filed before the Judicial Magistrate First class, Raipur

    District Raipur, CG.

    11. From the record, it is evident that the motorcycle on which the

    deceased was travelling as a pillion rider was being driven by Vikrant

    Singh. Upon examining the driving licence of the motorcycle rider, the

    learned Claims Tribunal observed that the licence was valid for the period

    from 04.05.2023 to 03.05.2033. Since the accident had occurred on

    18.01.2023, the Tribunal held that, on the date of the accident, Vikrant
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    Singh did not possess a valid and effective driving licence. The learned

    Claims Tribunal further observed that the appellants/claimants had failed

    to produce any documentary evidence or cogent oral evidence to establish

    that Vikrant Singh was duly authorized and competent to drive the

    motorcycle. On that basis, the Tribunal concluded that Vikrant Singh was

    also negligent. As the accident involved two vehicles, the Tribunal treated

    the case as one of contributory negligence and held that the

    appellants/claimants were entitled to only 50% amount of compensation.

    As stated above, the burden of proving Issue No. 4(C) was upon the

    respondents. However, for reasons best known to them, they neither

    examined any witness nor produced the driver of the offending vehicle to

    establish that the driver of the motorcycle had also contributed to the

    occurrence of the accident. It is well settled that proceedings under the

    Motor Vehicles Act for grant of compensation are summary in nature. The

    strict rules of evidence are not required to be applied in proving every fact.

    The Claims Tribunal is required to determine the issue on the touchstone of

    the preponderance of probabilities to ascertain whether the negligence of

    the driver of the offending vehicle stands established. The claimants cannot

    be expected to prove negligence in the same manner as is required in a

    criminal trial. In the present case, Issue No. 1 regarding the rash and

    negligent driving of the offending vehicle had already been decided in favour

    of the claimants. The learned Claims Tribunal recorded a finding of

    contributory negligence solely on the ground that the driver of the

    motorcycle did not possess a valid and effective driving licence on the date

    of the accident and, on that basis, deducted 50% amount of the

    compensation. The finding so recorded by the learned Claims Tribunal

    cannot be sustained for more than one reason. Firstly, the deceased was

    not driving the motorcycle; he was merely travelling as a pillion rider.

    Therefore, it cannot be said that the deceased had, in any manner,
    6

    contributed to the occurrence of the accident. Secondly, the learned Claims

    Tribunal erroneously treated the case as one of contributory negligence,

    whereas, at the highest, the facts of the case could have attracted the

    principle of composite negligence. The contributory negligence has been

    attributed in cases where the accident involved two motor vehicles, one of

    which was being driven by the deceased or the claimant, who sustained

    injuries in the accident. The Hon’ble Supreme Court in T.O. Anthony v.

    Karvarnan & Ors., (2008) 3 SCC 748, has drawn a clear distinction

    between contributory negligence and composite negligence, and held in

    paragraphs 6 & 7 as under:-

    “6. ‘Composite negligence’ refers to the negligence on
    the part of two or more persons. Where a person is
    injured as a result of negligence on the part of two or
    more wrongdoers, it is said that the person was injured
    on account of the composite negligence of those
    wrongdoers. In such a case, each wrongdoer is jointly
    and severally liable to the injured for payment of the
    entire damages and the injured person has the choice
    of proceeding against all or any of them. In such a
    case, the injured need not establish the extent of
    responsibility of each wrongdoer separately, nor is it
    necessary for the court to determine the extent of
    liability of each wrongdoer separately. On the other
    hand, where a person suffers injury, partly due to the
    negligence on the part of another person or persons,
    and partly as a result of his own negligence, then the
    negligence on the part of the injured which contributed
    to the accident is referred to as his contributory
    negligence. Where the injured is guilty of some
    negligence, his claim for damages is not defeated
    merely by reason of the negligence on his part but the
    damages recoverable by him in respect of the injuries
    stand reduced in proportion to his contributory
    negligence.”

    “7. Therefore, when two vehicles are involved in an
    7

    accident, and one of the drivers claims compensation
    from the other driver alleging negligence, and the other
    driver denies negligence or claims that the injured
    claimant himself was negligent, then it becomes
    necessary to consider whether the injured claimant
    was negligent and, if so, whether he was solely or
    partly responsible for the accident and the extent of his
    responsibility, that is his contributory negligence.
    Therefore, where the injured is himself partly liable, the
    principle of composite negligence will not apply nor can
    there be an automatic inference that the negligence
    was 50:50. The Tribunal ought to have examined the
    extent of contributory negligence…”

    12. The principal reason assigned by the Tribunal for recording such a

    finding was that the driver of the motorcycle was not holding a valid and

    effective driving licence on the date of the accident. This finding cannot

    sustain in the light of judgment of the Supreme Court in the case of Sudhir

    Kumar Rana v. Surinder Singh and ors., (2008) 12 SCC 436 in which it

    has been held in paragraph 9 as below –

    “9. If a person drives a vehicle without a licence, he
    commits an offence. The same, by itself, in our opinion,
    may not lead to a finding of negligence as regards the
    accident. It has been held by the courts below that it
    was the driver of the mini-truck which was being driven
    rashly and negligently. It is one thing to say that the
    appellant was not possessing any licence but no finding
    of fact has been arrived at that he was driving the two-
    wheeler rashly and negligently. If he was not driving
    rashly and negligently which contributed to the
    accident, we fail to see as to how, only because he was
    not having a licence, he would be held to be guilty of
    contributory negligence.”

    Thus, the finding of the learned Claims Tribunal on the issue of

    contributory negligence cannot withstand the scrutiny of this Court. Even
    8

    otherwise, the respondents failed to adduce any evidence to discharge the

    burden of proving Issue No. 4(C). Consequently, the finding with regard to

    contributory negligence is unsustainable in law and is hereby set aside.

    13. This led to know the second point of determination with regard award

    of just compensation. The deceased was working as Assistant Grade-III in

    the municipalities, Bemetara. According to AW-2 his basic pay was Rs.

    19500/- and adding the allowances his gross salary was Rs. 27166/- he

    has exhibited the salary slip of the deceased vide Ex.P-11. The learned

    Tribunal while assessing the compensation found that the brother of the

    deceased was given compassionate appointment thus the appellants /

    claimants are not entitled to any future prospect. Denying the future

    prospect by the learned claims Tribunal on account of compassionate

    appointment cannot sustain in the eye of law.

    14. The Hon’ble Supreme Court in case of Vimal Kanwar and Ors. Vs.

    Kishore Dan and Ors. Reported in (2013) 7 SCC 476 in paras 20 & 21

    held thus-:

    “20. The second issue is “whether the salary receivable
    by the claimant on compassionate appointment comes
    within the periphery of the Motor Vehicles Act to be
    termed as “Pecuniary Advantage” liable for deduction.”

    21. “Compassionate appointment” can be one of the
    conditions of service of an employee, if a scheme to that
    effect is framed by the employer. In case, the employee
    dies in harness i.e. while in service leaving behind the
    dependents, one of the dependents may request for
    compassionate appointment to maintain the family of the
    deceased employee dies in harness. This cannot be
    stated to be an advantage receivable by the heirs on
    account of one’s death and have no correlation with the
    amount receivable under a statute occasioned on
    account of accidental death. Compassionate appointment
    may have nexus with the death of an employee while in
    service but it is not necessary that it should have a
    9

    correlation with the accidental death. An employee dies
    in harness even in normal course, due to illness and to
    maintain the family of the deceased one of the
    dependents may be entitled for compassionate
    appointment but that cannot be termed as “Pecuniary
    Advantage” that comes under the periphery of Motor
    Vehicles Act
    and any amount received on such
    appointment is not liable for deduction for determination
    of compensation under the Motor Vehicles Act.”

    15. Thus, in light of the settled legal position, the learned Claims

    Tribunal erred in holding that the appellants/claimants were not entitled to

    addition towards future prospects merely because appellant No. 2 had been

    granted compassionate appointment. From the evidence available on

    record, it is evident that the deceased was working as an Assistant Grade-

    III and was a salaried employee. Ex. P-12C is the appointment order of the

    deceased dated 30.07.2017, which shows that he himself had been

    appointed on compassionate grounds. Ex. P-11 is the salary slip of the

    deceased, according to which his basic salary was Rs. 19,500/-. After

    adding dearness allowance, house rent allowance, computer allowance and

    other admissible allowances, his gross monthly salary was Rs. 27,166/-.

    Ex. P-3 the High School Certificate-cum-Mark Sheet, records the deceased’s

    date of birth as 03.03.1998. Since the accident occurred on 18.01.2023, the

    deceased was above 24 years but below 25 years of age on the date of the

    accident. Accordingly, in view of the law laid down by the Hon’ble Supreme

    Court in Smt. Sarla Verma and others VS. Delhi Transport Corporation

    and another reported in (2009) 6 SCC 121 and National Insurance Co.

    Ltd. Vs. Pranay Sethi reported in (2017) 16 SCC 680 and Magma

    General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram & Ors; (2018)

    18 SCC 130, this Court proceeds to recompute the compensation in the

    following manner:-

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     S. No.    Description                                  Amount
     1.        Monthly income                               27,166/-
     2.        Total Yearly Income (27166x12)               3,25,992/-
     3.        50% future prospect                          1,62,996/-
     4.        Income after future prospect                 4,88,988/-
    

    5. Income Tax Deduction 11,949.4/- (12,000/-) 12,000/-

    round figure

    6. Total income after deduction of income tax 4,76,988/-

    7. 1/2 Deduction 2,38,494/-

    8. Loss of dependency 18×238494 42,92,892/-

    9. Loss of estate 16,500/-

    10. Funeral expenses 16,500/-

    11. Filial Consortium to appellant No. 1 40,000/-

    Total 43,65,892/-

    16. Since learned Tribunal has already awarded a sum of Rs.

    19,90,952/-, the enhanced amount which he now is entitled to get

    comes to Rs. 23,74,940/-. Order accordingly.

    17. The amount of compensation shall be paid by the insurance

    company / respondent No. 3 within a period of 60 days with 6%

    interest, from the date of appeal i.e. 08.01.2024.

    18. After deposit Rs. 50,000/- shall be disbursed to appellant No. 2;

    Rs. 1,00,000/- shall be disbursed to appellant No. 3 and Rs.

    20,00,000/- of four different fixed deposit of Rs. 5,00,000/- (five lacs)

    each shall be invested in a nationalized bank for a period of three

    years in the name of appellant No. 1. Remaining amount shall be paid

    to appellant No. 1 through bank transaction/account payee cheque.

    19. Appeal thus partly allowed.

    Sd/-

    (Sachin Singh Rajput)
    JUDGE
    Pawan



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