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August 2025

The legal requirement of proximate cause for accidental death insurance coverage; the Supreme Court rejects a claim for death caused by a sunstroke while performing election duties.

Case Title: National Insurance Company Ltd. Versus The Chief Electoral Officer & Ors

The Supreme Court has ruled that a death caused by sunstroke while performing election duties is not covered by the insurance policy provision "death only resulting solely and directly from an accident caused by external violence and other visible means." The case involved a Memorandum of Understanding (MoU) established between the National Insurance Company and the Chief Electoral Officer of Bihar in 2000. The deceased's widow was entitled to insurance coverage under the MOU, but the insurance company filed an appeal with the Supreme Court.

The court determined that a plain and strict reading of the insurance policy is required, citing the 2019 precedent Alka Shukla vs Life Insurance Corporation Ltd. The court also highlighted the importance of plain pursuing the insurance policy. The court concluded that the 'Scope of Cover' in the insurance policy does not include a cause arising from a sunstroke, and the claim was beyond a reasonable time frame. The court restated the legal principles governing the interpretation of insurance policy clauses, including strict interpretation, the importance of interpreting contracts accurately, exceptions under equity, claims for the insured being limited to the amount explicitly protected by the policy, and the need for a direct causal connection between the motor vehicle collision and physical harm.

About the case

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