Case Name: MAHAVEER SHARMA v. EXIDE LIFE INSURANCE COMPANY LIMITED & ANR., Arising out of SLP (Civil) No. 2136 OF 2021
Summary of the Case:
The Supreme Court ruled that non-disclosure of other existing life insurance policies does not automatically warrant claim repudiation, as insurance contracts are based on utmost good faith. In this case, the insured had disclosed one major life insurance policy but failed to mention others of relatively insignificant value. The Court observed that the materiality of non-disclosed facts must be assessed on a case-to-case basis and concluded that in this instance, the non-disclosure did not impact the insurer’s decision to issue the policy. Consequently, the repudiation of the claim was deemed improper, and the insurer was directed to release all benefits under the policy along with an interest of 9% per annum.
Detailed Explanation:
The case involved an insurance policy taken by the appellant’s father from Exide Life Insurance for ₹25 lakhs. After his father’s death, the appellant submitted a claim, which was rejected on the grounds that the insured had not disclosed multiple smaller insurance policies, except for a ₹40 lakh policy from Aviva Life Insurance. The insurer argued that full disclosure of existing policies was a material fact that could impact risk assessment. However, the Supreme Court distinguished this case from previous rulings where complete non-disclosure influenced the insurer’s decision. Since the insured had already disclosed a significant policy and the omitted ones were of lower value, the Court held that such omission was not material enough to warrant repudiation. It further noted that the insured’s capacity to pay premiums was evident, as the insurer had issued the policy despite knowing about the Aviva policy. Therefore, the Court set aside the repudiation and directed the insurer to honor the claim with applicable interest.
