Case Title: Branch Manager, Life Insurance Corporation of India & Anr vs Banwari Lal Gupta
Case No.: RP/2513/2019
Summary
The National Consumer Disputes Redressal Commission (NCDRC) has ordered a nominee of the deceased to receive Rs. 10 Lakhs from the Life Insurance Corporation of India (LIC). The main point of contention was whether the death was a suicide or an accident. The NCDRC determined that the death was an accident, as the deceased’s viscera had positive levels of ethyl alcohol and aluminum phosphide, indicating the potential of poisoning by unidentified individuals.
The case concerned the sudden death of Jugal Kishor, a passenger on the Jan Shatabdi train who was purportedly poisoned after an attempted robbery. Banwari Lal Gupta, the brother of the deceased, filed a claim for insurance with the Life Insurance Corporation of India (the “Insurance Company”), requesting a double claim benefit for accidental death in the amount of Rs. 10 lakhs. However, the insurance company rejected the claim, disputing the cause of death and suggesting that the death might have been a suicide rather than an accidental poisoning death. The complainant used this rejection as cause to file a consumer complaint with the District Consumer Disputes Redressal Commission, Sawai Madhopur (the “District Commission”) against the insurance firm. The complaint was rejected by the District Commission.
The complainant appealed to the State Consumer Disputes Redressal Commission of Rajasthan (“State Commission”), which granted the appeal and overturned the District Commission’s decision. The NCDRC received a revision petition from the insurance firm, which was upset. The claimant claimed that the insurance policy stated clearly that an accidental death benefit of Rs. 10 lakhs will be paid out. The insurance company contested the claim, arguing that the deceased’s reports’ mention of ethyl alcohol and aluminium phosphide suggested a suicide rather than a poisoning accident.
After reviewing the deceased’s forensic and medical records, the NCDRC concluded that poisoning may have been the cause of an unintentional fatality. Rejecting the insurance company’s claims regarding suicide, the NCDRC concluded that the majority of the evidence suggested the likelihood of poisoning by unidentified individuals. The NCDRC consequently affirmed the State Commission’s ruling and ordered the insurance provider to compensate the complaint with Rs. 10 Lakhs, covering the insurance claim and benefits as well as 9% interest.
About the case
A nominee of the deceased has been ordered by the National Consumer Disputes Redressal Commission (“NCDRC”) bench, which is led by Dr. Inder Jit Singh (Presiding Member), to receive Rs. 10 Lakhs from the Life Insurance Corporation of India (LIC). The main point of contention was whether the death was a suicide or an accident. Considering medical records, police inquiries, and further data, the NCDRC determined that the death was an accident. It found that the deceased’s viscera had positive levels of ethyl alcohol and aluminum phosphide, indicating the potential of poisoning by unidentified individuals.
The case concerned the sudden death of Jugal Kishor (“Deceased”), a passenger on the Jan Shatabdi train, who was purportedly poisoned after an attempted robbery. This happened on July 10, 2010, which resulted in his admittance to the Railway Hospital in Gangapur City. He was then admitted to the SMS Hospital in Jaipur, where he tragically died on July 11, 2010. Banwari Lal Gupta, the brother of the deceased, filed a claim for insurance with the Life Insurance Corporation of India (the “Insurance Company”), requesting a double claim benefit for accidental death in the amount of Rs. 10 lakhs. But the insurance company rejected the claim, disputing the cause of death and suggesting that the death might have been a suicide rather than an accidental poisoning death. The complainant used this rejection as cause to file a consumer complaint with the District Consumer Disputes Redressal Commission, Sawai Madhopur (the “District Commission”) against the insurance firm.
The complaint was rejected by the District Commission. As a result, the complainant appealed to the State Consumer Disputes Redressal Commission of Rajasthan (“State Commission”), which granted the appeal and overturned the District Commission’s decision. The National Consumer Disputes Redressal Commission (“NCDRC”) received a revision petition from the insurance firm, which was upset.According to the claimant, the insurance policy stated clearly that an accidental death benefit of Rs. 10 lakhs will be paid out. Suicide, he claimed, was implausible in light of the overwhelming evidence that pointed to accidental death from external poisoning. In addition to underlining the lack of proof for the insurance company’s suicide claim, he pointed out that the dead had no known problems with family, work, or substance misuse.
Contrarily, the insurance company contested the claim, arguing that the deceased’s reports’ mention of ethyl alcohol and aluminium phosphide suggested a suicide rather than a poisoning accident. They contended that in such a case, certain clauses in the insurance policy would be triggered, relieving the business of any liability. The insurance provider further argued that the State Commission had misapplied the legislation and had failed to understand the case’s factual circumstances. They threw doubt on the legitimacy of the accidental death claim by pointing out that there was no concrete evidence of theft or external contamination. The State Commission’s decision to grant the complainant’s initial appeal was contested by the insurance company.
The first thing the NCDRC did was review the deceased’s forensic and medical records. According to these reports, ethyl alcohol and aluminum phosphide tests on the deceased’s viscera came back positive. The NCDRC noted that these materials did not provide clear evidence that the deceased had taken their own life by consuming them, notwithstanding the insurance company’s assertion that this indicated suicide. In addition to pointing out that there were no known problems in the deceased person’s life that would have led to suicide, the NCDRC noted that the insurance company had not shown any proof to back up the suicide claim. The NCDRC also took into account the circumstances leading up to the occurrence. It stated that because the dead was traveling in a train compartment with several passengers, it was improbable that someone outside the deceased’s alcohol could have forced poison into it.
There was no proof of poisoning found in the alcohol according to the Police Final Report, and neither conductors nor other passengers reported any theft to the authorities. These elements strengthened the case for accidental death and cast doubt on the veracity of the suicide allegation. After taking into account all available data and records, as well as the arguments put out by both sides, the NCDRC came to the conclusion that poisoning may have been the cause of an unintentional fatality. Rejecting the insurance company’s claims regarding suicide, the NCDRC concluded that the majority of the evidence suggested the likelihood of poisoning by unidentified individuals. The NCDRC consequently affirmed the State Commission’s ruling and ordered the insurance provider to compensate the complaint with Rs. 10 Lakhs, covering the insurance claim and benefits as well as 9% interest.
