In Sameem Begum & Ors v. K. Venkat Swamy & Anr. , the Supreme Court delivered a pivotal judgment, unequivocally affirming that the absence of dependency does not extinguish the right of a legal representative to claim compensation under the Motor Vehicles Act. The Court anchored its decision on the principle of devolution of estate rather than actual dependency, thereby clarifying that any person who in law represents the estate of the deceased is entitled to maintain a claim. This landmark ruling builds upon the foundation laid in Manjuri Bera vs. Oriental Insurance Company Limited and Another , National Insurance Company Limited v. Pranay Sethi , and Magma General Insurance Company Limited v. Nanu Ram , cementing the right of non-dependent heirs to be compensated for the loss of spousal, parental, or filial companionship. This decision encompasses not only spousal consortium but also parental and filial consortium, thereby acknowledging the profound and multifaceted loss of companionship, care, affection, guidance, and the irreplaceable familial bonds severed by the victim’s untimely demise.
