Page 55 - The Insurance Times February 2025

Legal Briefs

Legal Briefs

Life Insurance Corporation of India v. Om Ajesh Kumar v. National Insurance Co. Ltd.

Prakash Citation: 2024 INSC 993
Citation: 2024 INSC 870 Court: Supreme Court of India
Court: Supreme Court of India Date: December 5, 2024
Date: November 13, 2024
Overview:
Ajesh Kumar filed a claim under his vehicle insurance policy
Overview:
with National Insurance Co. Ltd., which was partially al-
This case involved a dispute over the repudiation of a life
lowed by the District Consumer Forum. The State Commis-
insurance claim by the Life Insurance Corporation of India
sion upheld this decision. However, the NCDRC, upon revi-
(LIC). The respondent, Om Prakash, had filed a claim follow-
sion, reduced the compensation amount. Ajesh Kumar ap-
ing the death of his wife, which LIC rejected on the grounds
pealed to the Supreme Court.
of alleged non-disclosure of material facts.
Key Issues:
Key Issues:
Revisional Jurisdiction: The scope of NCDRC's author-
Non-Disclosure: Whether the insured had failed to dis- ity to interfere with concurrent findings of lower con-
close pre-existing medical conditions at the time of sumer forums.
policy inception.
Quantum of Compensation: Appropriateness of the
Burden of Proof: The extent of the insurer's responsi- compensation awarded for the insurance claim.
bility to prove intentional suppression of material facts.
Judgment:
Judgment: The Supreme Court set aside the NCDRC's order,
The Supreme Court ruled in favor of Om Prakash, stating restoring the compensation amount determined by the
that LIC failed to provide conclusive evidence of deliberate District Forum and upheld by the State Commission. The
non-disclosure by the insured. The Court emphasized that Court held that the NCDRC exceeded its revisional jurisdic-
minor ailments not impacting the insured's health signifi- tion by re-evaluating factual findings without sufficient
cantly do not constitute material facts requiring disclosure. grounds.

Implications: Implications:
This judgment reinforces the principle that insurers must This judgment clarifies the limited scope of NCDRC's
provide clear evidence when alleging non-disclosure to re- revisional powers, emphasizing that it should not act as an
pudiate claims. It underscores the necessity for insurers to appellate body re-assessing facts unless there is a manifest
conduct thorough investigations before issuing policies and error or miscarriage of justice. It ensures that the decisions
highlights the importance of clear communication with poli- of lower consumer forums are given due deference, promot-
cyholders regarding disclosure requirements. ing judicial discipline and consistency.

50 February 2025 The Insurance Times