Income Tax Records of a Firm Cannot Prove Salary of a Specific Employee in Absence of Foundational Evidence: Punjab & Haryana High Court Declines Interference in MACT Summoning Order

“Summary nature of MACT proceedings cannot be stretched into a fishing inquiry when claimants fail to produce even basic proof like bank statements or salary slips” —  In a notable ruling Punjab and Haryana High Court dismissed a civil revision petition filed by the legal heirs of a motor accident victim, seeking interference under Article 227 of the Constitution with an order of the Motor Accident Claims Tribunal (MACT), Karnal, which had refused their request to summon Income Tax Department records and employer’s salary details to prove the deceased’s alleged income.

Justice Nidhi Gupta held that the petitioners had failed to establish even a rudimentary factual basis to justify the summoning of the Income Tax Clerk and employer’s documents, and that the Tribunal’s refusal did not suffer from any legal error or perversity.

The Court made it unequivocally clear that:

“Income tax documents of the firm alone cannot prove payment to a specific employee without direct correlation.”

The High Court emphasized that when the petitioners could not produce the deceased’s bank statement or any proof of actual salary payment, their attempt to summon bulk records of the firm, M/s Nafe Singh & Sons, amounted to a speculative and unjustified exercise, incompatible with the summary character of motor accident compensation proceedings.

“Claimants Must Prove What They Can Before Asking the Court to Prove the Rest”: Tribunal Not Bound to Entertain Unfounded Summoning Requests

The case revolved around a motor accident compensation claim under Section 166 of the Motor Vehicles Act, 1988, filed by the wife and children of deceased Satyawan, who allegedly worked at M/s Nafe Singh & Sons on a monthly salary of ₹20,000. To prove this income, the petitioners filed an application to summon the Income Tax Clerk along with three years of income tax returns and salary records of the firm.

Justice Nidhi Gupta noted that the petitioners did not produce even a bank statement, salary slip, or appointment letter of the deceased. When queried by the Court as to why no financial record was available from the deceased’s side, counsel for the petitioners submitted that salary was partly paid in cash, but could not specify the exact period or months.

This prompted the Court to observe:

“Petitioners have themselves failed to produce the account statement of the deceased to prove his income in the first instance… The ostensible reason cited for summoning the witness is not made out.”

The Tribunal had earlier refused the request, stating that merely pointing to the firm’s large turnover and general salary disbursement figures was insufficient, as these figures did not specifically relate to Satyawan’s employment.

The High Court upheld that reasoning, reiterating:

“The existence of a firm’s audit report showing salary disbursements is not relevant unless the claimants can first show a direct connection between the deceased and the alleged employer.”

“Article 227 Cannot Be Used to Micromanage Tribunal’s Procedural Discretion”: High Court Declines to Interfere with Interlocutory Order

The High Court reaffirmed the limited scope of supervisory jurisdiction under Article 227, stating that it is not intended to monitor every procedural order passed by subordinate tribunals unless there is “manifest perversity or jurisdictional error”.

Rejecting the petitioners' plea, the Court held:

“No ground is made out to set aside the impugned order… The Tribunal rightly exercised discretion based on the lack of foundational material.”

It was further observed that MACT proceedings are meant to deliver timely compensation through summary adjudication, and not become avenues for unending documentary inquiries, especially when the party seeking those records has not discharged its initial evidentiary burden.

Thus, the High Court concluded that there was no material irregularity in the Tribunal’s approach and that its refusal to allow the summoning application was not only legally sound, but also consistent with the objective of motor accident claims proceedings.

The judgment in Santro and Others v. Bittu and Others stands as a clear pronouncement on the limits of evidence gathering in summary proceedings under the Motor Vehicles Act. It sends an unambiguous message that claimants cannot demand broad-based summoning of third-party records without first producing basic material to establish relevance and necessity.

Justice Nidhi Gupta’s ruling ensures that MACTs are not burdened with speculative discovery processes, and that judicial discretion in managing such procedural requests will not be lightly disturbed. The verdict strikes a balance between claimants' rights to fair adjudication and the need for procedural economy and evidentiary discipline.

Date of Decision: 16 October 2025