In Alka Shukla V Life Insurance Corporation of India, the Supreme Court comprising Justice D.Y. Chandrachud and Justice Hemant Gupta found that there was no evidence to show that any injury suffered because of a fall from the motorcycle led to the insured having a heart attack. The insured died because of a heart attack which was not related to the accident. Hence, the insurer was correct to repudiate the claim of the insured under the accidental benefit component of the insurance policy.
The insured obtained three insurance policies from the Life Insurance Corporation of India. The policies were payable only if the insured sustained any bodily injury resulting solely and directly from the accident caused by “outward, violent and visible means” leading to his death. Insurance company repudiated the claim on the ground that the insured died because of a heart attack and not an accident. The appellant filed a consumer complaint before the district forum and district forum directed the insurance company to pay the insurance amount under the three policies along with interest. The State Commission confirmed the order given by the district forum. The insurer filed the revision petition before the National Commission and the commission reversed the order of district forum and set aside the award of compensation. Award passed by the National Commission is challenged before the Supreme Court of India.
Supreme Court observed that, claim, in case of an accident, is payable only if the following conditions are satisfied: The insured sustained injuries directly and solely from the accident; the accident was caused by violent, outward and visible means; and that injury solely and directly of other causes results in the death of the insured person.
Supreme Court in the present case held that there is no evidence to show that any bodily injury was suffered due to fall from the bike or that led to the insured suffering a heart attack. There is no evidence to show that the accident took place as a result of any violent, outward and visible means. For the reasons stated above, Supreme Court is of the view that judgment of the NCDRC does not suffer from any error and the appeal shall stand dismissed.
