Case: Life Insurance Corporation of India vs. Dr. Nilam Hetalkumar Patel & 4 Ors.
Summary
The Life Insurance Corporation of India (LIC) appealed against an order from the Gujarat State Consumer Disputes Redressal Commission (SCR) but was denied by the National Consumer Disputes Redressal Commission (NCDRC). The NCDRC directed LIC to reimburse the complainant’s beneficiaries for Rs 47.90 lakh, as the claims were rejected on the grounds that the complainant had not disclosed material facts at the time of policy issuance. Anil Kumar Patel, a resident of Kheda, Gujarat, had acquired nine life insurance policies from LIC but died from a heart attack within two years. The Patel family applied to the District Commission, which issued a partial ruling in favor of the nominees. LIC filed a challenge to the Gujarat State Consumer Disputes Redressal Commission, but their appeal was dismissed. The NCDRC upheld the decision, citing the Supreme Court’s decision in Satwant Kaur Sandhu vs. The New India Assurance Co. Ltd (2009) 8 SCC 316, which underscored the absence of a physician’s affidavit when the insured party has granted the insurance company permission to obtain medical information from hospitals.
About the case
The appeal by the Life Insurance Corporation of India (LIC) against an order of the Gujarat State Consumer Disputes Redressal Commission was denied by the National Consumer Disputes Redressal Commission (NCDRC) bench, which is under the leadership of Inder Jit Singh (Presiding Member). The NCDRC directed LIC to reimburse the complainant’s beneficiaries for Rs 47.90 lakh because the claims were rejected on the grounds that the complainant had not disclosed material facts at the time of policy issuance.
A resident of Kheda, Gujarat, Anil Kumar Patel had acquired nine life insurance policies from the LIC. Mr. Patel passed away from a heart attack within two years of obtaining these policies, which is a tragic loss. The nominees of Mr. Patel, who were entitled to the insurance benefits, submitted claims for all of the aforementioned life insurance policies after his untimely death. As a result of Mr. Patel’s failure to disclose material circumstances during the policy issuance, the claims were denied by LIC. The Patel family subsequently applied to the Kheda District Consumer Disputes Redressal Forum (“District Commission”) in order to assert their rights. The District Commission issued a partial ruling in favor of the nominees. LIC filed a challenge to the decision before the Gujarat State Consumer Disputes Redressal Commission (“State Commission”) in response to its dissatisfaction with the outcome. However, their appeal was dismissed. Finally, LIC submitted an appeal to the National Consumer Disputes Redressal Commission (“NCDRC”) as a last resort.
As the complainants in this case, the nominees of Mr. Patel argued that the medical certificate regarding Mr. Patel’s depression should be disregarded as evidence. This was their stance due to the absence of the requisite corroborating affidavit from the physician who had issued the certificate. In addition, the nominees contended that LIC’s panel physicians had conducted medical examinations of Mr. Patel prior to the issuance of the policies, and that an additional premium had been assessed as a result of Mr. Patel’s excess weight. Their argument was that this demonstrated that no material information had been concealed or suppressed.
On the other hand, LIC maintained that Mr. Patel had indeed withheld material information regarding his medical history and treatment. However, LIC maintained that the repudiation of the insurance claims was justified by this non-disclosure. Their argument was that the repudiation of the claims was valid due to Mr. Patel’s failure to disclose material information.
During the State Commission proceedings, Mr. Patel’s nominees contended that a medical certificate regarding his melancholy should not be accepted as evidence because the doctor who issued it did not provide an affidavit. In spite of this, the certificate was admitted into evidence by the State Commission. The NCDRC, in agreement with the State Commission, upheld this decision. The Supreme Court’s decision in Satwant Kaur Sandhu vs. The New India Assurance Co. Ltd (2009) 8 SCC 316 was cited by the NCDRC, which underscored the absence of a physician’s affidavit when the insured party has granted the insurance company permission to obtain medical information from hospitals. Consequently, the NCDRC determined that the certificate should be considered admissible. Therefore, the NCDRC denied LIC’s appeal and directed the company to distribute a total of Rs. 47.90 lakh to Mr. Patel’s nominees.
