insurance policy

Narbada Devi and Ors. Vs. H.P. State Forest Corporation & Anr. [Civil Appeal No. 6379 of 2010]

Insurance company not liable as the death caused is not of accident

Brief: In the instant Civil Appeal, the Hon’ble Supreme Court held that insurance company not liable for compensation as the death of the insured was not accidental which was pre-requisite as per the terms of insurance policy. Further, the insured was admittedly drunk at the time of death and thus, the liability of the insurer company was further exempted.

RELEVANT PARAGRAPH

12. From a bare perusal of the Insurance Policy, as quoted supra, it is clear that only if the insured sustains any bodily injury   resulting   solely   and   directly   from   accident   caused   by outward, violent   and   visible   means, the   Insurance   Company would be liable to indemnify the insured. Therefore, as per the Insurance Policy, only accidental death of the insured shall be indemnified. As noted above, the Post­Mortem Report   clearly indicates that there were no injuries found on the body of the deceased. The probable cause of death as per the Final Opinion in the Post­Mortem Report is asphyxiation caused by alcohol consumption and regurgitation of food into larynx. As such, we find   it   difficult   to   conclude   that   the   deceased’s   death   was accidental. Further, the expert opinions of Dr. D.S. Puri and Dr. D.J. Das Gupta (supra) also show that the cause of death was due to consumption of alcohol. In light of the explicit terms of the Insurance Policy, we find that the National Commission and the State Commission have rightly held that the deceased’s death was not accidental, and that the Insurance Company would not be liable to settle the Appellants’ claim.

17. Be   that   as   it   may, the   Provisos   of   insurance   policy specifically disclose that compensation will not be paid in respect of injury of the injured if he is under the influence of intoxicating liquor. The relevant Proviso 4 of the insurance policy reads thus:­

“PROVISOS
Provided always that the company shall not be liable under this policy to:
4) Payment of compensation in respect of death, injury   or   disablement   of   the   insured   from (a) intentional (illegible) suicide or attempted suicide, (b)   whilst   under   the   influence   of   intoxicating liquor   or   drug   (c)   or   (illegible)   by   insanity,   (d) arising or resulting from the insured committing any breach of the law with criminal intent.”

The   aforesaid   Proviso   4   makes   it   amply   clear   that   the injured is not entitled to compensation since on facts it is proved that he was intoxicated and that was due to intoxication.

18. In light of the aforementioned observations, we decline to interfere   with   the   Impugned   Order   passed   by   the   National Commission. Accordingly, the Appeal stands dismissed. No order as to costs.