Case Title: Life Insurance Corporation Of India Vs. Rohini Swami
Case Number: R. P. No. 3456/2016
In a significant decision from the National Consumer Disputes Redressal Commission, a previous ruling by the State Commission was overturned in favor of Life Corporation Of India. The chair of the commission, Justice Sudip Ahluwalia, ruled that proper evidence is necessary to prove death by poisoning in an insurance claim. In this case, the State Commission had failed to provide such evidence.
Let’s delve into the case details.
The complainant’s husband had taken out an insurance policy from Life India Insurance. The policy was worth Rs. 5,00,000 and included an extra Rs. 5,00,000 as accidental death benefits, totaling to Rs. 10,00,000. After undergoing a medical examination and paying the premium, the policy was issued. Unfortunately, the husband fell ill with symptoms of acidity and vomiting and later passed away. An initial post-mortem report suggested possible poisoning. However, a later report found no poison, and the insurer denied the complainant’s claim because of discrepancies regarding the husband’s alcohol consumption and suspicion of suicide by poisoning.
After filing a complaint with the District Forum, the Forum directed the insurer to pay Rs. 5,00,000, plus Rs. 2,000 for mental agony and Rs. 1,000 for litigation costs. The complainant, not fully satisfied, appealed to the State Commission, which ordered the insurer to also pay the accidental death benefit of Rs. 5,00,000. The insurer then filed a revision petition with the National Commission.
The insurer argued that the deceased had been a heavy drinker, based on the medical summary. They also pointed out that the deceased had falsely declared not consuming alcohol when he applied for the policy. The insurer argued that the cause of death could have been intentional poisoning, not an accident. They also referred to a Supreme Court case, Mahabir Mandal and Ors. Vs. State of Bihar, which stated that some poisons might not leave traces detectable in post-mortem examinations.
The Commission, after examining the evidence, found that while there were suspicions of poisoning, no concrete proof was found. The final police report and the Regional Forensic Science Laboratory of Maharashtra confirmed that no poison was detected. The Commission noted that the State Commission had concluded death by poisoning without substantial evidence and had overlooked the deceased’s history of alcoholism and recent consumption, which could have contributed to his demise.
In light of these findings, the National Consumer Disputes Redressal Commission overturned the State Commission’s decision and upheld the original verdict of the District Forum, thereby allowing the insurer’s revision petition.
In conclusion, this case underscores the importance of substantial evidence in insurance claim disputes, especially in cases involving death by poisoning. It’s a reminder to all policyholders to provide accurate information at the time of policy issuance to avoid complications in the event of a claim.