The Supreme Court of India on Thursday, 11 June ruled that a municipal authority cannot be held liable under the Motor Vehicles Act (MVA) for injuries sustained when a tree branch fell on a stationary autorickshaw during heavy rain, holding that such an incident does not arise out of the 'use of a motor vehicle' as contemplated under the law. The bench, however, invoked its extraordinary powers under Article 142 of the Constitution to enhance compensation for the grievously injured claimant from ₹17.10 lakh to ₹25 lakh.

Background: The Bengaluru Incident of 2007

The case traces back to 23 June 2007, when respondent K.K. Umesh Kumar was travelling in an autorickshaw from Queens Road to Chinnaswamy Stadium in Bengaluru. Caught in heavy rain, the driver pulled over and parked beneath a roadside tree. A branch detached from the tree and crashed onto the vehicle, leaving the passenger with permanent paraplegia along with bladder and bowel incontinence — injuries the court described as 'life-altering'.

A Motor Accident Claims Tribunal initially dismissed the compensation claim, classifying the incident as a natural calamity. After multiple rounds of litigation, the Karnataka High Court awarded ₹17.10 lakh in compensation, apportioning liability as follows: 25% to the Bruhat Bengaluru Mahanagara Palike (BBMP), 50% to the autorickshaw's insurer, and 25% to the state's Horticulture Department. The BBMP challenged this apportionment before the Supreme Court.

What the Supreme Court Held on MVA Liability

A bench of Justice Sanjay Karol and Justice N. Kotiswar Singh examined whether the incident could be classified as arising out of the 'use of a motor vehicle' under Section 166 of the MVA. The court held it could not. 'The motor vehicle itself does not play an active role in the accident. It is not part of the proximate cause of the accident. For that reason, a claim under Section 166 specifically may not be appropriate,' the bench observed.

Notably, the court reasoned that had the claimant been standing under the tree as a pedestrian rather than seated in the autorickshaw, the outcome would have been identical — underscoring the absence of a causal link between the vehicle and the accident. 'The unfortunate falling of a branch was within contemplation of neither any authority nor even the driver of the autorickshaw,' the bench said.

Civic Duty and Its Limits

While ruling in favour of the BBMP on the MVA question, the court did not absolve municipal bodies of their general duty of care. The bench acknowledged that corporations are obligated to maintain roadside trees — not merely for their health, but to prevent hazards to the public. 'A tree has been on the side of the road for many years. Because it is part of the city, the Municipal Corporation does have a duty to ensure that those trees are looked after,' the bench said.

At the same time, the court struck a calibrated note, cautioning that 'it would be unrealistic to expect that authorities of the Corporation can maintain a constant vigil over each tree/shrub.' This balance between civic accountability and operational practicality is significant for how future negligence claims against urban local bodies may be framed.

Article 142 and Enhanced Compensation

Despite settling the legal question against the claimant on the MVA front, the Supreme Court said it could not, in good conscience, leave a person suffering permanent paralysis without adequate relief. Describing the Karnataka High Court's award as based on a 'somewhat technical approach', the bench enhanced the total compensation to ₹25 lakh with interest accruing from the date of filing of the claim petition.

The existing apportionment of liability among the BBMP, the insurer, and the Horticulture Department was left undisturbed. All parties were directed to deposit their respective shares within four weeks. 'It is within our domain, as the final Court of the country, to ensure the law, as implemented, especially in cases like these, is humane and in accordance with the salutary principles of the Constitution,' the bench declared.

Implications for Future Claims

This judgment draws a clear line between accidents causally linked to vehicle use and those where a vehicle is merely incidental to the harm. It signals that claimants injured by falling trees, collapsing infrastructure, or similar hazards while in a parked vehicle may need to pursue remedies outside the MVA framework — potentially under tort law or state-specific compensation schemes. Urban local bodies, meanwhile, face renewed scrutiny over tree-maintenance protocols, even as the court acknowledged the limits of what can reasonably be demanded of them.