On 1 July 2026, the Delhi High Court ruled that claims under the personal accident cover of a motor insurance policy cannot be decided by the Motor Accident Claims Tribunal (MACT). The judgment clarified that such claims arise from the insurance contract and are governed by policy terms, not the provisions of the Motor Vehicles Act, 1988.
The Court further stated that disputes related to personal accident cover claims must be addressed before the appropriate forum, such as a consumer forum, rather than the MACT.
Background of the Case
The case, Simbal Singh v. Amarjit Singh & Anr., stemmed from a fatal road accident that occurred on 2 January 2022. Udey Singh alias Uday Jit Singh was driving his father Amarjit Singh's insured Toyota Innova when it was allegedly struck from behind by an unidentified truck. The impact caused the Innova to collide with another car before crashing into a roadside wall. Udey Singh died in the accident, while the truck fled the scene and could not be traced, resulting in the incident being treated as a hit-and-run case.
Following the accident, the deceased's mother filed a compensation claim before the MACT. She was the appellant in the case, Simbal Singh v. Amarjit Singh & Anr. Instead of pursuing a claim against the unidentified truck, she sought compensation from the insurer of the Innova, arguing that the vehicle was covered under a Comprehensive/Package Motor Insurance Policy that included personal accident cover and occupant coverage. She contended that her son, although driving the vehicle, should be treated as an occupant or third party under the policy and that the insurer was liable to compensate his legal heirs.
Delhi High Court's Judgment
On 1 July 2026, Justice Anish Dayal of the Delhi High Court dismissed the appeal and upheld the MACT's decision, holding that claims seeking benefits under the personal accident cover of a motor insurance policy cannot be adjudicated by the Motor Accident Claims Tribunal. The Court clarified that such claims are contractual in nature and must be decided according to the terms and conditions of the insurance policy before the appropriate forum, such as the consumer forum or any other competent authority.
While delivering the judgment, Justice Anish Dayal observed:
"What is quite clear to this Court is that... A claim made under Section 166 of the MV Act involves proof of negligence against the driver of the vehicle, which, in this case, was the deceased himself and, therefore, liability could not have been placed on the owner, which would then be covered by the insurer."
The Court further held:
"The claim, if made under the personal accident cover of the insurance policy, would be tested on the terms and conditions of the insurance contract and, therefore, would not be within the remit of MACT... Expanding the jurisdiction of MACT to cover claims of this nature would be extending the motor accidents jurisprudence to an illogical extremity."
Accordingly, the Court ruled that while the claimants remain free to seek benefits under the personal accident cover, they must pursue those remedies through the insurer and, if necessary, before the consumer forum or another competent forum, rather than the MACT.
Why the Court Rejected the Claim
The Court's decision was based on the following legal principles:
A claim under Section 166 of the Motor Vehicles Act requires proof of negligence. Since the alleged offending truck could not be identified, negligence against another vehicle could not be established.
Motor accident compensation and personal accident cover operate under different legal frameworks. The Court clarified that compensation under the Motor Vehicles Act is based on statutory liability, whereas personal accident cover is governed by the terms of the insurance contract.
The MACT's jurisdiction is limited to claims under the Motor Vehicles Act. It cannot adjudicate disputes that require interpretation of contractual rights under an insurance policy.
Contractual insurance claims must be pursued before the appropriate forum. If a claimant seeks benefits under a personal accident cover and the insurer rejects the claim, the dispute must be taken to the consumer forum or another competent forum instead of the MACT.
What This Judgment Means for Motor Insurance Policyholders
The Delhi High Court's ruling reinforces the distinction between statutory motor accident claims and contractual insurance benefits. While a motor insurance policy may include personal accident cover, policyholders should note that disputes relating to these benefits cannot automatically be brought before the Motor Accident Claims Tribunal (MACT).
Some takeaways from the judgment include:
Personal accident cover is contractual:
MACT has limited jurisdiction:
Policy wording matters:
Alternative legal remedies remain available:
Any claim under this cover will be assessed according to the terms and conditions of the motor insurance policy rather than the provisions of the Motor Vehicles Act.
The Tribunal can decide claims arising under the Motor Vehicles Act, but it cannot adjudicate disputes that primarily involve interpreting an insurance contract.
Whether a claimant is entitled to benefits under a personal accident cover depends on the specific policy terms, including who is covered and under what circumstances.
If an insurer rejects a claim under the personal accident cover, the policyholder or claimant may approach the consumer forum or another competent forum to seek relief.
Conclusion
This judgment reinforces that the forum for resolving an insurance claim depends on its legal nature. While MACT deals with statutory motor accident claims, disputes over personal accident cover must be pursued under the insurance contract.
Read Complete Judgement – https://www.verdictum.in/pdf_upload/2026/07/04/simbal-singh-v-amarjit-singh-1780404.pdf
Frequently Asked Questions
Can a personal accident cover claim be filed before the MACT?
No. As clarified by the Delhi High Court, claims arising solely from the personal accident cover of a motor insurance policy are contractual in nature and cannot be adjudicated by the Motor Accident Claims Tribunal (MACT). Such claims must be pursued before the appropriate forum under the insurance contract.
How does a MACT claim differ from a personal accident insurance claim?
A MACT claim is made under the Motor Vehicles Act for compensation arising from a motor accident, usually based on statutory liability. A personal accident insurance claim, on the other hand, is based on the terms and conditions of the insurance policy and is contractual in nature.
Where should a policyholder file a personal accident cover dispute?
If an insurer rejects a claim under the personal accident cover, the policyholder or claimant can approach the consumer forum or any other competent forum, depending on the nature of the dispute.
Does comprehensive motor insurance allow PA claims before MACT?
No. Even if a comprehensive motor insurance policy includes personal accident cover, disputes regarding those benefits cannot automatically be decided by the MACT. The claimant's rights depend on the policy terms and the appropriate legal forum.