Page 56 - The Insurance Times August 2025

Insurance Caselaws

The legal requirement of proximate cause established between the National Insurance Company and the
for accidental death insurance coverage; Chief Electoral Officer of Bihar in 2000. The purpose of this
agreement was to ensure that individuals assigned to the
the Supreme Court rejects a claim for 2000 assembly elections were adequately insured. A mem-
death caused by a sunstroke while per- ber of the election duty staff perished as a result of sunstroke
contracted during the course of his responsibilities.
forming election duties.
On the issue before the Supreme Court was whether, pur-
Case Title: National Insurance Company Ltd. suant to the aforementioned clause, the deceased's widow
Versus The Chief Electoral Officer & Ors was entitled to insurance coverage under the MOU. Once
the widow was granted relief by the Patna High Court, the
Summary insurance company filed an appeal with the Supreme Court.
The Supreme Court has ruled that a death caused by sun- A panel of judges consisting of Justices SK Kaul and AS Oka
stroke while performing election duties is not covered by the granted the insurer's appeal and determined that the de-
insurance policy provision "death only resulting solely and mise caused by sunstroke was not covered by the terms of
directly from an accident caused by external violence and the policy. The guiding principle is A straightforward and
other visible means." The case involved a Memorandum of rigorous interpretation of the insurance policy. As a guiding
Understanding (MoU) established between the National principle for interpreting an insurance policy, the Court de-
Insurance Company and the Chief Electoral Officer of Bihar termined that a plain and strict reading is required. In de-
in 2000. The deceased's widow was entitled to insurance termining what constitutes an "accidental death" within the
coverage under the MOU, but the insurance company filed context of an insurance policy, the 2019 precedent Alka
an appeal with the Supreme Court. Shukla vs Life Insurance Corporation Ltd. was cited.
The court determined that a plain and strict reading of the The Court noted, in reference to the precedent, that "a di-
insurance policy is required, citing the 2019 precedent Alka rect causal connection between the accident and the bodily
Shukla vs Life Insurance Corporation Ltd. The court also high- injury is required." Additionally, as a guiding principle, the
lighted the importance of plain pursuing the insurance policy. significance of plain pursuing the insurance policy was em-
The court concluded that the 'Scope of Cover' in the insur- phasized. "Irrespective of the strict interpretation of the
ance policy does not include a cause arising from a sunstroke, clauses, it is obvious from a simple reading that the claim is
and the claim was beyond a reasonable time frame. The admissible only in the event of death." Only "only" is used
court restated the legal principles governing the interpre- to commence the second part of the provided sentence.
tation of insurance policy clauses, including strict interpre- Therefore, even in the case of a fatality, the subsequent
tation, the importance of interpreting contracts accurately, circumstance can only materialize in the given scenario;
exceptions under equity, claims for the insured being lim- specifically, it must be a tragedy directly caused by external
ited to the amount explicitly protected by the policy, and violence. Here, mortality is caused by a solar stroke. No
the need for a direct causal connection between the motor evidence suggested that violence contributed to the fatal-
vehicle collision and physical harm. ity. The final element that appears as "any other visible
About the case means" should be interpreted within the framework of ejus-
dem generis pertaining to the external violent demise; it
The Supreme Court has ruled that a death caused by sunstroke
while performing election duties is not covered by the insur- should not be interpreted independently.
ance policy provision "death only resulting solely and directly Consequently, the court reached the following conclusion:
from an accident caused by external violence and other vis- "From our perspective, the 'Scope of Cover' in the insurance
ible means." A Memorandum of Understanding (MoU) was policy, which specifies the time at which the insurance

50 August 2025 The Insurance Times