Motor Accident Claims Cannot Be Decided on Sympathy – Involvement of Offending Vehicle Must Be Proved: Supreme Court

“Law Requires Evidence, Not Emotion – Standard of Preponderance of Probabilities Not Met,” On 12 December 2025, a bench of the Supreme Court comprising Justice Sanjay Karol and Justice Prashant Kumar Mishra  dismissing appeals filed by the legal heirs of two deceased victims of an alleged road accident, after holding that the involvement of the offending vehicle was not established even on the threshold of preponderance of probabilities, the standard applicable under Section 166 of the Motor Vehicles Act, 1988.

While acknowledging the tragic loss of two young lives, the Court made it clear that compensation under the MV Act cannot be awarded in the absence of credible and reliable evidence proving the essential elements of the claim.

Involvement of Vehicle Not Proved, Witnesses Contradictory, Evidence Unreliable

The Court ruled that “mere filing of a chargesheet is not conclusive proof of liability”, and “sympathy cannot override the requirement of legal proof under Section 166 of the MV Act.”

The appeals were directed against a common judgment of the Karnataka High Court, which had affirmed the dismissal of two separate compensation claims by the Motor Accident Claims Tribunal (MACT), Shimoga. Both courts had found glaring inconsistencies and contradictions in the witness testimonies, and serious evidentiary lapses, such as the absence of the vehicle registration number in the FIR, a delayed spot mahazar, and a Motor Vehicle Inspector’s report showing no damage to the allegedly offending vehicle.

Fatal Accident Alleged, but Vehicle Link Not Proved

The appellants—legal heirs of Sunil Singh (26) and Shivu (22)—alleged that on 14 August 2013, while returning from Honnali on a motorcycle, both deceased were fatally hit by a Canter lorry bearing Reg. No. KA20-AA-6786, allegedly driven rashly by respondent No.1. Based on this, two separate claim petitions were filed under Section 166 MV Act.

However, the MACT, after examining the material evidence, found no credible proof of the offending vehicle’s involvement. The High Court agreed, dismissing the appeals. The matter then came before the Supreme Court.

“Standard is Preponderance, But Even That Not Met,” Observes the Court

While reiterating that “in accident claims, the standard of proof is not that of criminal trials, but rather preponderance of probabilities”, the Supreme Court underlined that even this lower threshold had not been met.

Justice Prashant Kumar Mishra, delivering the judgment, stated:

“The claimants must establish the specific identity of the vehicle or driver. The connection between the accident and the said vehicle must be shown through cogent and reliable evidence. In the present case, that evidentiary link is missing.”

Tribunal and High Court Not in Error – Findings Are Concurrent and Well Reasoned

The Court held that the findings of the Tribunal and the High Court were based on detailed and reasoned assessments of the evidence, and do not suffer from any perversity. Relying on Collector Singh v. L.M.L. Limited, Kanpur, (2015) 2 SCC 410, the bench reminded that interference with concurrent findings of fact under Article 136 of the Constitution is only warranted in exceptional circumstances, such as gross misappreciation of evidence—which was not the case here.

Witness Testimony: Contradictory and Lacking Credibility

The Supreme Court meticulously examined the testimonies of P.W.1 (Parashuram Singh) and P.W.2 (Parmesh)—both close relatives of the deceased—and found them to be inconsistent and lacking direct knowledge of the incident. Neither had witnessed the accident. Their statements were based on hearsay, with multiple contradictions regarding the source of their information.

Even P.W.3 and P.W.4, who claimed the driver confessed to the accident, were found highly unreliable. The Court observed:

“Testimony that the driver voluntarily confessed and revealed registration numbers appears inherently improbable and contrary to normal human conduct.”

Both witnesses contradicted themselves during cross-examination, with one admitting he did not know who caused the accident and the other stating he had no knowledge of the vehicle involved.

Chargesheet, MVI Report, and FIR – No Corroboration Found

The Court noted that a chargesheet was filed, but only after the alleged offending vehicle was recovered one and a half months post-accident—raising doubts about its probative value. The Motor Vehicle Inspector’s (MVI) report, dated 5 October 2013, recorded no damage to the vehicle, despite the claim that it was involved in a fatal head-on collision.

The FIR also failed to mention the registration number of the offending vehicle, and the spot mahazar was prepared after a significant delay, further weakening the appellants’ case.

“Omissions at the FIR stage are not always fatal, but when combined with other evidentiary deficiencies, they cannot be ignored,” the Court noted.

Sympathy Cannot Substitute Legal Proof, Says the Court

In a poignant observation, the Court remarked:

“We are deeply conscious of the tragic loss suffered by the families… However, the principles of law cannot be set aside on the grounds of sympathy alone. Liability under the MV Act must be established through credible evidence.”

Accordingly, finding no perversity in the concurrent findings, and no exceptional ground to interfere, the appeals were dismissed.

The ruling stands as a firm reminder that motor accident compensation claims, despite their humanitarian dimension, are governed by principles of evidence and legal standards. The Supreme Court emphasized that even the preponderance of probabilities must be supported by consistent and reliable evidence, and sympathy cannot override statutory mandates.

Date of Decision: 12 December 2025