Is there any relevance of implications of section 45 of the Insurance Act (As amended by the Insurance Laws (Amendment) Act, 2015 related to this case ?

Yes, there is a relevance. Section 45 of the Insurance Act, 1938 provides the remedy to a Life Insurer for breach of the condition of utmost good faith on the part of the life assured. It gives the right to the Life insurer to repudiate a claim under a Life Insurance policy if there was a misstatement, concealment or misrepresentation on any fact which was material to consideration of the risk by a Life insurer. The amended Section 45 outlines conditions under which an insurance company can repudiate a policy: Within the First Three Years: An insurance company can repudiate a policy within the first three years from the date of issuance if there is evidence of misrepresentation, fraud, or non-disclosure of material facts by the policyholder. The onus is on the insurer to prove that the policyholder had the intention to suppress facts or mislead the insurer. After Three Years: After three years from the issuance of the policy, the insurance policy cannot be called into question on any ground whatsoever. This means that if the policy has been in force for more than three years, the insurer cannot repudiate the claim on the grounds of misrepresentation, fraud, or non-disclosure. As per section 45 (Insurance Laws Amendment Ordinance on 26 December, 2014) by the above amendment act, a 3-year time limit has been fixed for any cancellation of policy or repudiation of claim on the above grounds. The policy in this case was taken in the year August, 2020 and death took place in the year September, 2023. As per this amendment Insurance policies cannot be repudiated after three years of the commencement of the policy. The policy is more than three years old, the insurer is generally prohibited from repudiating the claim based on non-disclosure or misrepresentation, and must honor the policy regardless of the smoking habit disclosure.