NATIONAL INSURANCE CO. LTD. vs LAXMI NARAIN DHUT

The Supreme Court clarified that the principles established in National Insurance Co. Ltd. v. Swaran Singh (2004 (3) SCC 297) apply only to third-party claims under Section 149 of the Motor Vehicles Act, 1988. The Court held that claims involving only the insurer and the insured do not fall under the same principles, necessitating a fresh examination by the High Courts and Commissions. The judgment emphasized the need for a purposive interpretation of the Motor Vehicles Act, distinguishing between third-party and non-third-party claims.