VidhiSangh

Supreme Court of India · 25/02/2025

MAHAVEER SHARMA versus EXIDE LIFE INSURANCE COMPANY LIMITED & ANR.

[2025] 2 S.C.R. 1311 · 2025 INSC 268

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Summary

The Supreme Court held that a life insurer could not repudiate a claim for non-disclosure of other policies where the insured had disclosed, and supplied a copy of, a larger existing life policy and omitted only policies of inconsequential sum assured. The disclosure was substantial, the omission would not have influenced a prudent insurer, and death was accidental under a life (not Mediclaim) cover; the claim was ordered to be paid with 9% interest.

Issues

  1. Whether the insured's failure to disclose three existing LIC policies, while disclosing an existing Aviva life policy, amounted to suppression of a material fact entitling the insurer to repudiate the life insurance claim.
  2. What constitutes a 'material fact' in a proposal for insurance, and how the decision in Rekhaben Nareshbhai Rathod applies to a case of partial disclosure.

Provisions considered

Held

Result

Appeal allowed; repudiation letter dated 03.03.2016 and the orders of the State and National Commissions set aside; insurer directed to release all policy benefits with interest at 9% per annum from the date due until realisation; no order as to costs.

Judgment PDF: Supreme Court of India, [2025] 2 S.C.R. 1311.