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Supreme Court of India 2021-04-12 allowed

IFFCO TOKIO GENERAL INSURANCE COMPANY LTD vs PEARL BEVERAGES LTD

Bench: 3 — Uday Umesh Lalit, Indira Banerjee, K.M. Joseph

In Brief

A car insured against own damage was involved in a severe accident when the driver crashed into a footpath, electric pole, and wall, causing the vehicle to overturn and catch fire. The insurer denied the claim, invoking a policy exclusion for accidents when the driver is under the influence of intoxicating liquor. The National Consumer Dispute Redressal Commission (NCDRC) had held that without a formal blood or breath test showing alcohol levels above 30 mg/100 ml of blood (as per Section 185 of the Motor Vehicles Act), the exclusion clause could not apply. The Supreme Court reversed this, holding that an insurer can invoke the exclusion clause based on circumstantial evidence—including smell of alcohol detected by medical staff, the severity and inexplicability of the accident, the driver's young age, consumption of alcohol by both occupants, and the driver's plea of guilty to rash and negligent driving—without requiring a formal breath analyzer or blood test. The Court held that the contractual term 'under the influence of intoxicating liquor' is broader than the criminal standard under Section 185 and can be established through the totality of circumstances in summary consumer proceedings.

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Insurance Law Consumer Protection Motor Vehicle Insurance Exclusion Clauses Intoxication and Driving

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