Procedural lapses by legal representatives should not prejudice the substantive rights of claimants

Case Citation

Court Name: Supreme Court of India
Case Title: T.C. John @ Yohannan (Deceased) through LRs v. V.J. Antony and Others
Case No.: Civil Appeal No. 14749 of 2024 (arising out of S.L.P. (C) No. 6313 of 2024)
Date of Judgment: December 19, 2024
Judges: Justice J.K. Maheshwari and Justice Rajesh Bindal

Facts of the Case

The case arose from a motor vehicle accident on August 7, 2006, where the deceased was traveling in a jeep with his wife and children when a bus collided with their vehicle, resulting in his death. The deceased’s family, comprising his widow and three daughters, filed a compensation claim before the Motor Accidents Claims Tribunal (MACT) for ₹15,00,000. The Tribunal awarded ₹4,15,000 with interest at 7.5% per annum, to be paid by the bus driver, owner, and insurance company. Aggrieved by the quantum of compensation, the claimants filed an appeal before the High Court after a delay of 708 days, which was condoned. The High Court enhanced the compensation by ₹9,84,500 but denied interest for specific periods due to procedural delays attributed to the claimants’ counsel. The present appeal before the Supreme Court concerned the denial of interest for the periods of delay.

Contentions of the Appellant

1. Insufficient Compensation: The appellant-claimants argued that the compensation awarded by the Tribunal was inadequate as the deceased’s income was not properly assessed, resulting in unfair computation.
2. Interest Denial Unfair: They contended that the denial of interest for the periods of delay was unjust as the procedural lapses were due to the counsel’s fault, not theirs.
3. Economic Hardship: Highlighting their dire financial condition, the appellants pleaded for fair treatment, as the deceased was the sole breadwinner of the family.

Contentions of the Respondent

1. Compensation Adequate: The respondents, represented by the insurance company, argued that the compensation awarded by the High Court was already on the higher side and did not warrant further enhancement.
2. Justified Denial of Interest: The respondents justified the denial of interest, citing the appellants’ delays in filing the appeal and providing necessary documents, which delayed proceedings.

Issues on Judgment

1. Whether the denial of interest for the delay in filing the appeal (708 days) was justified?
2. Whether the appellants-claimants should be deprived of interest for the period from June 22, 2016, to July 13, 2023, due to delays in providing documents?
3. Whether procedural lapses by the appellants’ counsel can be equated to negligence by the appellants themselves?

Observations/Findings by the Supreme Court

The Supreme Court acknowledged the procedural delays but differentiated between delays attributable to the appellants directly and those caused by their counsel. The Court observed:

1. Delay in Filing Appeal: The High Court’s condition of denying interest for the 708-day delay in filing the appeal was reasonable, as the appellants were directly responsible for the lapse.
2. Procedural Lapses During Pendency: The denial of interest for the period from June 22, 2016, to July 13, 2023, was unjustified, as the procedural delays during pendency were not solely attributable to the appellants but largely to their counsel. The appellants, being poor and illiterate, should not suffer for their counsel’s shortcomings.

Principles Laid Down by the Court

1. Fairness in Compensation: Courts must ensure just compensation for victims of motor vehicle accidents, taking into account the financial hardships of claimants.
2. Differentiating Fault: Procedural lapses by legal representatives should not prejudice the substantive rights of claimants, especially in cases involving economic hardship.
3. Reasonable Conditions on Delays: While condoning delays, courts can impose reasonable conditions, but such conditions must not disproportionately penalize claimants for factors beyond their control.

Final Order

The Supreme Court partly allowed the appeal, modifying the High Court’s order to grant interest on the enhanced compensation for the period from June 22, 2016, to July 13, 2023, at the same rate of 8% per annum. The Court upheld the denial of interest for the 708-day delay in filing the appeal, recognizing it as the appellants’ responsibility.

Importance of this Judgment to Society

This judgment highlights the judiciary’s role in balancing procedural rigor with substantive justice, ensuring that underprivileged litigants are not unduly penalized for technical delays. By holding that procedural lapses by counsel should not compromise the rights of claimants, it strengthens access to justice for marginalized groups. The decision also reinforces the importance of fairness in compensatory frameworks, particularly in motor accident claims, providing clarity on the interplay of procedural and substantive law in such cases.