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Supreme Court of India 2025-11-13 allowed

Kopargaon Sahakari Sakhar Karkhana Ltd. (Now known as Karmaveer Shankarrao Kale Shahkari Shakhar Karkhana Ltd.) vs National Insurance Company Ltd. & Anr

Bench: 2 — Pamidighantam Sri Narasimha, Manoj Misra

In Brief

A sugar factory's boiler, certified fit under the Indian Boilers Act, exploded in May 2005 during an active insurance policy. The insurer repudiated the claim on grounds of wear, tear, and corrosion of tubes, citing an exclusion clause. The National Consumer Disputes Redressal Commission reversed the State Commission's award relying on a belated surveyor's report. The Supreme Court held the repudiation unjustified: the boiler's statutory fitness certificate created a presumption of safety; the explosion itself was the proximate cause of loss, not corrosion; no material nondisclosure was proved; and exclusion clauses cannot defeat insurance's main purpose. The appeal was allowed, the NCDRC judgment set aside, and the matter remanded on quantum alone.

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Insurance Contract Law Consumer Protection Boiler & Pressure Plant Insurance Exclusion Clauses Utmost Good Faith Indian Boilers Act Proximate Cause Burden of Proof Statutory Presumption Deficiency in Service

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