Clarifying Liability of Minors as Mere Passengers in Motor Vehicle Accidents

Introduction

The case of Sachin Yallappa Usulkar & Ors. v. Vijayata & Ors. (2025 INSC 290) reached the Supreme Court of India and raised a critical question: can a minor who is merely a passenger in a motor vehicle be held liable for a fatal accident? Originating from an incident in which the registered owner’s minor son was alleged to have driven the offending vehicle, this matter addressed issues of negligence in motor vehicle accidents, evidentiary standards for ascribing liability, and the proper method for determining compensation.

The background of the dispute centers on a fatal accident wherein the victim’s family sought significant compensation, alleging that the deceased was struck and dragged by a Bolero vehicle driven by a minor. The Motor Accident Claims Tribunal (“Tribunal”) awarded damages, finding the minor responsible. The High Court of Karnataka upheld both the liability assignment and the enhancement of compensation from the Tribunal’s award. However, the registered owner and the alleged minor driver appealed to the Supreme Court, disputing the factual finding regarding the minor’s role. Ultimately, the Supreme Court clarified that when a minor is merely seated beside the driver, he or she cannot be deemed liable without cogent proof of actual involvement in the accident.

Summary of the Judgment

In its final decision, the Supreme Court upheld the enhancement of compensation payable to the victim’s family but overturned the finding of liability against the minor occupant. Specifically, the Court clarified:

1. The registered owner’s minor son was merely a passenger and was not driving the vehicle at the time of the accident.
2. All allegations that he was the one driving the vehicle lacked concrete evidence and contradicted multiple eyewitness accounts.
3. The father of the minor was in fact the individual at the wheel, and therefore any liability for negligent driving could not be attributed to the minor occupant.
4. The Court refused to interfere with the quantum of compensation the High Court awarded to the deceased’s family, but absolved the minor entirely from the accident-related liability.
5. The direction given by the lower courts that the Insurance Company could recover losses from the minor occupant and owner was set aside as against the minor co-passenger. However, the Insurance Company was not absolved from its ultimate liability to pay compensation to the claimants.

Analysis

A. Precedents Cited

The Court cited its earlier decision in Sajeena Ikhbal v. Mini Babu George (2024 INSC 787), referencing the principle that, ordinarily, in appeals filed under Article 136 of the Constitution of India, the Supreme Court does not reappreciate evidence. However, the Court noted that it may still examine the correctness of findings where they appear to be perverse or manifestly incorrect. This principle laid the foundation for the Court’s willingness to reanalyze the factual matrix surrounding the minor’s alleged involvement.

Another pertinent reference was the decision in Mangla Ram v. Oriental Insurance Co. Ltd. & Ors. (2018) 5 SCC 656, which served to reinforce the Supreme Court’s prerogative under Article 136 to correct errors in evidence appreciation made by lower courts.

B. Legal Reasoning

The Supreme Court recognized that the legal question at the core was whether a minor occupant could be held responsible for causing the accident. The Court systematically reanalyzed the record:

• Eyewitness Accounts: The most telling aspect was the testimony from multiple eyewitnesses, including the deceased’s own friend, who confirmed that the father of the minor was the person driving the offending vehicle. These testimonies undermined any claim that the minor was at the wheel.
• Contradictory Statements: The Court found inconsistencies in the record that the lower courts had not reconciled properly. While initial reports indicated that the minor was implicated in the police complaint, sworn statements in the courtroom made it clear that he was not operating the vehicle.
• Lack of Direct Evidence: With no firm or verifiable evidence linking the minor to driving and with witnesses testifying otherwise, the Court concluded that the lower courts reached a “perverse finding” on this liability issue.
• Principle of “Pay and Recover”: Although the High Court had directed the Insurance Company to pay compensation and subsequently recover it from the owner and alleged minor driver, the Supreme Court found this direction to be unjustified as far as the minor occupant was concerned.

Consequently, the Court held that the minor occupant could not be deemed liable in the absence of unambiguous evidence of his control over the vehicle. This is broadly in line with the principle that liability should be grounded in demonstrable fault, and in the context of minors, the requirement of proof is even more stringent.

C. Impact

This decision is significant for several reasons. First, it underscores the importance of rigorous evidentiary standards in motor accident claims, especially where a minor is alleged to be the operator of a vehicle. Second, it affirms that merely naming an individual (particularly a minor) in an FIR or police complaint does not automatically establish liability. Finally, it shapes the scope of the “Pay and Recover” principle, clarifying that the insurer’s right to recover from the owner or any implicated driver must rest on solid findings about who was actually driving at the time of the accident.

Going forward, tribunals and courts will likely exercise greater caution when evaluating allegations against minors in motor vehicle accident claims. Insurance companies, litigants, and legal practitioners will need to ensure that legitimate evidence supports claims of a minor driving a vehicle, given the higher risk of erroneous accusations against minors.

Complex Concepts Simplified

Two main legal concepts stand out in the Judgment and often cause confusion:

1. Article 136 of the Constitution of India: This provision allows the Supreme Court to grant special leave to appeal against any judgment from lower courts or tribunals. While the top court typically does not re-evaluate the factual matrix, it may step in when findings are deemed perverse or plainly incorrect. In this case, it re-examined the evidence because the lower courts appeared to have ignored clear testimonies.
2. The “Pay and Recover” Principle: In motor accident claims, courts may direct the insurance company to first compensate the victim(s) and then recover the sum from the party liable. However, the Court stressed that this principle should be applied only when the party from whom recovery is sought has been established, through credible evidence, to be at fault. Here, the minor was wrongly implicated, so the insurance company could not seek recovery from him.

Conclusion

The Supreme Court’s ruling in Sachin Yallappa Usulkar & Ors. v. Vijayata & Ors. (2025 INSC 290) sets a crucial precedent on apportioning liability in motor vehicle accidents. By underscoring that a minor occupant cannot be deemed responsible in the absence of clear, credible proof, the Court ensured that liability is not casually assigned based on mere allegations, especially where vulnerable parties are concerned.

The Judgment therefore achieves a dual objective: it rightly maintains compensation for the deceased’s family for their irreplaceable loss, while clarifying that a minor passenger who is not in control of the vehicle at the time of the accident cannot be compelled to bear the burden of liability. In a broader context, it reaffirms fundamental evidentiary standards and underscores the judiciary’s readiness to correct factual missteps, ensuring just and equitable outcomes in motor accident litigation.