Supreme Court Judgment in S. Rajaseekaran v. Union of India (2025 INSC 45)

Introduction

The Supreme Court judgment in S. Rajaseekaran v. Union of India addresses the critical issue of providing timely and cashless treatment for road accident victims during the “golden hour.” This judgment reviews Sections 162 and 164-B of the Motor Vehicles Act, 1988 (MV Act), introduced to ensure immediate medical care to accident victims. The Court underscores the need for expeditious implementation of the statutory provisions by the Central Government.

Background

The case arose from a writ petition filed to ensure effective implementation of measures under the amended MV Act, specifically focusing on cashless treatment for road accident victims. Section 162 of the MV Act, effective from April 1, 2022, mandates the Central Government to establish a scheme for cashless treatment during the golden hour, defined under Section 2(12-A) as the one-hour period following a traumatic injury when prompt medical care has the highest likelihood of preventing death. Section 164-B further provides for the creation of the Motor Vehicle Accident Fund to finance such treatments.

Despite the legislative mandate, the Central Government had not formulated the requisite scheme, prompting judicial intervention.

Key Observations and Legal Comments

1. Golden Hour and the Right to Life: The Court linked the golden hour scheme to Article 21 of the Constitution, which guarantees the right to life. It reiterated that denying immediate medical treatment during the golden hour could result in loss of life, rendering the statutory provisions ineffective.
2. Central Government’s Obligation: The Court noted that more than sufficient time had passed since the introduction of Sections 162 and 164-B. While acknowledging the creation of the Motor Vehicle Accident Fund and associated rules (Central Motor Vehicles Rules, 2022), the Court expressed concern over the absence of an operational scheme for cashless treatment.
3. Reference to Precedents: The judgment referred to Parmanand Katara v. Union of India (1989), where the Court held that no injured person should be denied immediate medical attention regardless of procedural requirements. This principle was echoed to emphasize the urgency of golden hour treatment.
4. Draft Concept Note Critique: The Court reviewed the draft concept note submitted by the Ministry of Road Transport and Highways. Concerns were raised over its limitations, including a treatment cap of Rs. 1,50,000 and a maximum duration of seven days. The Court emphasized that such limitations could undermine the purpose of the scheme and directed necessary revisions.
5. Pending Claims and Procedural Delays: The Court addressed delays in settling claims under the hit-and-run scheme managed by the General Insurance Council (GIC). Observing deficiencies in document submissions and portal development, the Court directed GIC to expedite claim settlements and enhance its digital infrastructure.

Directives Issued by the Court

1. Scheme Implementation: The Central Government was directed to frame and implement a comprehensive scheme under Section 162(2) of the MV Act by March 14, 2025. The scheme’s details and an affidavit explaining its implementation must be submitted to the Court by March 21, 2025.
2. Claim Settlement: GIC was instructed to process pending claims based on seven specified documents, including FIRs, injury or post-mortem reports, and ID proofs. GIC was also directed to coordinate with state authorities to address document deficiencies and establish a functional portal for claim management by March 14, 2025.
3. Monitoring Compliance: The Court set the next hearing for March 24, 2025, to review compliance with its directions, including the operational status of the cashless treatment scheme and claim settlement processes.

Legal and Policy Implications

1. Golden Hour Scheme: The judgment highlights the urgency of operationalizing the golden hour scheme, emphasizing its potential to save lives. The Court’s intervention ensures that statutory provisions are not rendered meaningless due to bureaucratic inertia.
2. Accountability of the Central Government: By setting strict deadlines and requiring detailed affidavits, the Court reinforced governmental accountability in implementing legislative mandates.
3. Strengthening Procedural Efficiency: The directives to GIC reflect the Court’s focus on streamlining procedural bottlenecks in claim settlements, ensuring timely relief to victims and their families.

Conclusion

The Supreme Court’s judgment in S. Rajaseekaran v. Union of India exemplifies the judiciary’s proactive role in safeguarding constitutional rights and ensuring effective implementation of welfare-oriented legislation. By addressing systemic delays and mandating concrete action, the Court has laid the groundwork for a robust framework to protect road accident victims during the critical golden hour.

References

1. Parmanand Katara v. Union of India, (1989) 4 SCC 286.
2. Motor Vehicles Act, 1988 (as amended in 2019).
3. Central Motor Vehicles (Motor Vehicle Accident Fund) Rules, 2022.
4. S. Rajaseekaran v. Union of India, 2025 INSC 45.