Medical History In MRI Report Recorded For Diagnosis Cannot Override Consistent Testimony & FIR In Motor Accident Claims: Supreme Court

"The isolated wording in the history column cannot displace the cumulative evidentiary record... a narration of facts [in medical history] cannot be treated as a precise reconstruction of the mechanics of the accident." Supreme Court, in a significant ruling dated May 25, 2026, held that motor accident claims cannot be dismissed merely on the basis of isolated entries in medical reports that contradict the claimant's testimony and the police record.

A bench of Justice Vikram Nath and Justice Sandeep Mehta observed that medical history recorded during emergency treatment is primarily intended to facilitate diagnosis and should not be treated as a definitive account of how an accident occurred.

The original claimant, a brick-field labourer, filed a claim under Section 163A of the Motor Vehicles Act, 1988, after being struck by a lorry in 2004, which resulted in permanent paraplegia. Both the Motor Accident Claims Tribunal and the Calcutta High Court dismissed the claim, primarily relying on an MRI report entry stating "fall from lorry," which contradicted the claimant’s assertion that he was hit by the vehicle after getting down from a rickshaw.

The primary question before the court was whether minor discrepancies in medical documentation and oral testimony can defeat a claim under the Motor Vehicles Act. The court was also called upon to determine whether the standard of proof beyond reasonable doubt is applicable to such summary proceedings and if a delay in filing an FIR is fatal to a claim involving grievous injuries.

Standard Of Proof In Welfare Legislation

The Court emphasized that proceedings under the Motor Vehicles Act are summary in nature and aimed at providing expeditious justice to victims. It reiterated that a claim petition must be decided on the touchstone of preponderance of probability rather than the rigorous standard of proof beyond reasonable doubt.

"Claim petitions are to be decided on the touchstone of preponderance of probability and not proof beyond reasonable doubt."

The bench noted that in claims under Section 163A, the enquiry is even narrower as negligence is not required to be proved. The court held that it is sufficient to demonstrate that the injury is reasonably connected with the motor vehicle in question, and minor contradictions that do not go to the root of the matter cannot defeat a substantive claim.

Medical History vs. Cumulative Evidentiary Record

Addressing the discrepancy in the MRI report, the Court observed that medical history recorded at the time of emergency treatment is often based on information supplied by attendants. Its primary function is to aid diagnosis, not to provide a precise reconstruction of the accident's mechanics.

"Medical history is ordinarily based on information supplied by attendants and its only function is to facilitate the diagnosis."

The bench held that the FIR, the chargesheet, and the claimant’s own testimony consistently indicated that he was hit by the lorry. The Court ruled that an isolated wording in a "history column" of a medical report cannot be allowed to displace the cumulative weight of the consistent documentary and oral evidence placed on record.

Delay In FIR And Absence Of Independent Witnesses

The Court rejected the High Court’s reliance on the delay in lodging the FIR to cast doubt on the claim. It observed that in cases involving life-altering injuries, the priority of the victim and their family is naturally to secure medical treatment rather than attending to legal formalities.

"Priority is given to securing medical treatment rather than attending to legal formalities; delay in approaching the police cannot lead to an inference that the accident did not occur."

Furthermore, the Court held that a claim cannot be rejected solely for the want of independent witnesses if the claimant’s own testimony has not been shaken in cross-examination. It noted that the approach in accident cases should be to analyze the existing evidence to see if it satisfies the requirement of probability, rather than finding fault with the non-examination of "best" eyewitnesses.

Hyper-Technical Approach Undermines Protective Purpose Of Statute

The Court cautioned against adopting a hyper-technical approach in adjudicating claims under the Act. It noted that accident victims are seldom in a position to procure precise documents or provide a perfectly coherent narration of events while undergoing intense medical treatment for serious injuries.

"The adjudicatory process must remain sensitive to the practical realities in which accident victims approach the Tribunal."

The bench observed that elevating minor inconsistencies into major hurdles would undermine the protective and welfare-oriented purpose of the Motor Vehicles Act. It stated that when the overall material establishes the accident and resulting injuries, trivial errors ought not to defeat the entitlement to substantive relief.

Exercise Of Article 142 For Just Compensation

Observing that the case had been pending for over two decades and that the claimant had since passed away, the Court invoked its jurisdiction under Article 142 of the Constitution. It decided to determine the compensation itself rather than remanding the matter, noting that the "structured formula" under the old Section 163A would be inadequate for 100% permanent disability.

"Strict confinement to Section 163A would not serve the interests of justice... we deem it appropriate to determine compensation by drawing guidance from principles evolved under Section 166."

The Court applied the principles laid down in Sarla Verma and Pranay Sethi to calculate "just compensation," emphasizing that the lack of legal awareness in invoking the "wrong" provision should not deny a victim fair recompense once the foundational facts of the accident are established.

The Supreme Court set aside the judgments of the High Court and the Tribunal, allowing the appeal and awarding a total compensation of Rs. 14,90,000/- with 6% interest. The ruling reinforces the principle that medical documentation must be read in the context of its clinical purpose and cannot be used to mechanically override consistent testimony in social welfare litigations.

Date of Decision: May 25, 2026