Reliance Life Insurance Co Ltd. vs Rekhaben Nareshbhai Rathod

Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2019 Supreme(SC) 487

D.Y.CHANDRACHUD, HEMANT GUPTA
Reliance Life Insurance Co Ltd. – Appellant
Versus
Rekhaben Nareshbhai Rathod – Respondent

Advocates Appeared:
For the Appellant :Mr. E.R. Kumar, Advocate, Mr. Aditya Sharma, Advocate, Ms. Swati Bhardwaj, Advocate, Mr. Raghav Bansal, Advocate, Mr. Manu Bajaj, Advocate, For M/S. Parekh & Co
For the Respondent:Mr. Snehasish Mukherjee, Advocate.

Judgement Key Points

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JUDGMENT

Dr. Dhananjaya Y. Chandrachud, J.

Leave granted.

2. This appeal is from a decision of the National Consumer Disputes Redressal Commission (NCDRC) dated 20 February 2015. The State Consumer Disputes Redressal Commission (SCDRC) at Ahmedabad allowed an appeal of the insured - respondent and sustained a claim under a policy of life insurance. This decision has been upheld in revision by the NCDRC. The insurer is hence in appeal.

3. On 10 July 2009, the spouse of the respondent took a policy of life insurance from Max New York Life Insurance Co Ltd, for a sum of Rs 11 lakhs. Barely two months thereafter, on 16 September 2009 he submitted a proposal for a life insurance term plan policy of the appellant for an insurance cover of Rs 10 lakhs. Among the questions that the proposer was required to answer in the proposal form was whether he was currently insured or had previously applied for life insurance cover, critical illness cover or accident benefit cover. This query was answered in the negative. Item 17 of the proposal form required a disclosure of:

"DETAILS OF LIFE INSURANCE POLICIES HELD/PROPOSALS APPLIED WITH LIFE INSURANCE COMPANIES (INCLUDING EXISTING POLICIES WITH RELIANCE

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Judicial Analysis

No cases in the provided list are explicitly identified as overruled, reversed, abrogated, or otherwise treated as bad law. All references indicate positive or neutral judicial treatment.

All cases in the list refer to the same core precedent: **Reliance Life Insurance Co. Ltd. & Anr. v. Rekhaben Nareshbhai Rathod** (various citations including (2019) 6 SCC 175, II (2019) CPJ 53(SC), 2019 (6) SCALE 734, etc.). This case is consistently followed, applied, or relied upon across all entries.

**Group Explanation**:

Specific examples:

Branch Manager, Bajaj Allianz Life Insurance Company Ltd. VS Dalbir Kaur - 2021 0 Supreme(SC) 81: "has set aside the judgement of the NCDRC" (Supreme Court in Rekhaben overturned NCDRC, strengthening Rekhaben as good law).

Mahakali Sujatha VS Branch Manager, Future Generali India Life Insurance Company Limited - 2024 3 Supreme 657: "Placing reliance on Rekhaben, the NCDRC observed that Sahara India had been overruled in Rekhaben" (Rekhaben overruled another case, but Rekhaben itself is positively cited).

Birla Sun Life Insurance Co. Ltd. VS Konchada Ravi Kumar - Consumer (2019): One partial negative ("is not applicable" and "this assertion cannot be accepted"), but still cited as "observed," not overruled.

Thematic consistency: Rekhaben is authoritative on insurance principles like material fact disclosure, suppression, misrepresentation, signature consequences, and policy repudiation (e.g., Star Health & Allied Insurance Company Ltd. vs Vineet Khanna - 2021 Supreme(Online)(Del) 4373, Sunita v. HDFC Standard Life Insurance Co. Ltd. - 2021 Supreme(Online)(Del) 4585, Pramod Kumar v. HDFC Standard Life Insurance Company Ltd. - 2023 Supreme(Online)(Del) 18292, SONIA vs LIFE INSURANCE CORPORATION OF INDIA & ANR. - 2024 Supreme(Online)(NCDRC) 521, SMT. LONGASHREE W/O LATE SH. RAJENDRA SINGH TOMAR & ANR vs LIFE INSURANCE CORPORATION OF INDIA - 2025 Supreme(Online)(NCDRC) 6336, ANURADHA ALIAS SHOBHA vs THE BRANCH MANAGER, LIFE INSURANCE CORPORATION OF INDIA - 2025 Supreme(Online)(NCDRC) 2667).

**Note on Birla Sun Life Insurance Co. Ltd. VS Konchada Ravi Kumar - Consumer (2019)**: Minor distinction ("not applicable in the present case"), but not criticized or overruled; treated as persuasive authority.

Birla Sun Life Insurance Co. Ltd. VS Konchada Ravi Kumar - Consumer (2019): "Ltd. and Ors. Vs. Rekhaben Nareshbhai Rathod (supra) is not applicable in the present case. ... this assertion cannot be accepted."

**Explanation**: Explicitly distinguished on facts/specific assertion, but not disapproved; remains valid law elsewhere.

None. All treatments are clear based on explicit language (e.g., no ambiguous phrasing like "questioned," "criticized," or partial quotes without context indicating negativity). Minor variations in citation (e.g., "Rathod" vs. "Rathore") do not affect treatment.

2019 Supreme(SC) 487

D.Y.CHANDRACHUD, HEMANT GUPTAReliance Life Insurance Co Ltd. – AppellantVersusRekhaben Nareshbhai Rathod – Respondent

Cases Referred (7)

Judicial Analysis

D.Y.CHANDRACHUD, HEMANT GUPTA
Reliance Life Insurance Co Ltd. – Appellant
Versus
Rekhaben Nareshbhai Rathod – Respondent