MV Act Claims Must Be Decided On Preponderance Of Probability, Not Proof Beyond Reasonable Doubt: Supreme Court

"Standard of proof beyond reasonable doubt cannot be applied while considering the petition seeking compensation on account of death or injury in a road traffic accident. It is a settled position of law that a claim petition is to be decided on the touchstone of preponderance of probability," Supreme Court, in a significant judgment dated May 25, 2026, held that motor accident claim petitions must be adjudicated on the touchstone of preponderance of probability rather than the strict criminal law standard of proof beyond reasonable doubt.

A bench of Justice Vikram Nath and Justice Sandeep Mehta observed that minor discrepancies in medical records or oral testimony should not be used to defeat the purpose of a welfare legislation intended to provide expeditious justice to accident victims.

The Court made these observations while setting aside concurrent findings of the Motor Accident Claims Tribunal and the Calcutta High Court, which had dismissed a claim petition on the grounds that the claimant failed to prove the factum of the accident due to "glaring discrepancies" in the record.

The case originated from an accident on May 21, 2004, where the claimant, a brick-field labourer, was allegedly knocked down by a lorry after alighting from a rickshaw. The injuries resulted in traumatic paraplegia and 100% permanent disability. Both the Tribunal and the High Court dismissed the claim under Section 163A of the Motor Vehicles Act, 1988, citing contradictions between the MRI report (which mentioned a 'fall from lorry') and the claimant's testimony (stating he was 'hit by a lorry'), alongside a delay in filing the FIR and a minor error in the vehicle number mentioned during cross-examination.

The primary question before the court was whether minor contradictions in documentation and oral testimony are sufficient to render the occurrence of an accident improbable in summary proceedings under the Motor Vehicles Act. The court also examined the appropriate standard of proof for such claims and whether compensation under Section 163A must be strictly confined to the structured formula of the Second Schedule when it fails to provide "just compensation."

Standard Of Proof In Welfare Legislation

The Court emphasized that proceedings under the Motor Vehicles Act are summary in nature with an aim to provide expeditious justice. It reiterated that the standard of proof beyond reasonable doubt is inapplicable to such cases. The bench noted that in a claim under Section 163A, the enquiry is even narrower as negligence is not required to be proved; it is sufficient that the injury is reasonably connected with the motor vehicle in question.

Court Distinguishes Between Fatal Discrepancies And Minor Imperfections

The bench observed that courts must differentiate between contradictions that render an accident improbable and those that merely reflect imperfections in documentation. It noted that the High Court and Tribunal had adopted a hyper-technical approach by focusing on isolated errors rather than the cumulative evidentiary record which established the accident.

"The Court must differentiate between contradictions that render the accident improbable and those that merely reflect imperfections in documentation. It is in this framework that the evidence needs to be appreciated."

Medical History Is For Diagnosis, Not Accident Reconstruction

Addressing the discrepancy in the MRI report, the Court held that medical history recorded during emergency treatment is often based on information from attendants and serves only to facilitate diagnosis. Such narrations cannot be treated as a precise reconstruction of the mechanics of the accident. The bench held that the FIR, chargesheet, and the claimant’s consistent testimony outweighed the isolated wording in a medical history column.

Delay In FIR Not A Ground To Doubt Genuine Claims

The Court ruled that delay in lodging an FIR cannot be a ground to doubt a claimant’s case, especially when the victim has suffered grievous injuries. Citing the precedent in Ravi v. Badrinarayan, the bench noted that priority is naturally given to securing medical treatment over legal formalities. Since the claimant was hospitalised for several months, the delay in approaching the police did not lead to an inference that the accident did not occur.

"It is natural that in cases involving grievous injuries, priority is given to securing medical treatment rather than attending to legal formalities. Delay in approaching the police cannot by itself lead to an inference that the accident did not occur."

Testimony Of Claimant Sufficient Even Without Independent Witnesses

On the issue of non-examination of independent witnesses, the Court held that if the claimant’s own testimony has not been shaken in cross-examination, the claim cannot be rejected solely for want of additional evidence. Relying on Sunita v. Rajasthan State Road Transport Corporation, the Court stated that the approach should be to analyze whether the evidence on record is sufficient on the touchstone of probability.

Exercise Of Article 142 Jurisdiction For Just Compensation

While the claim was filed under Section 163A, the Court observed that the structured formula in the Second Schedule (as it stood then) was inadequate for a victim with 100% permanent disability. Invoking its extraordinary jurisdiction under Article 142 of the Constitution, the Court applied principles evolved under Section 166 of the Act to ensure "just compensation," citing the evolution of law in Sarla Verma and Pranay Sethi.

"Strict confinement to Section 163A would not serve the interests of justice. Therefore, in exercise of our jurisdiction under Article 142 of the Constitution, we deem it appropriate to determine compensation by drawing guidance from the principles evolved in claims arising under Section 166."

The Supreme Court concluded that the lower courts applied an erroneously high threshold of proof akin to criminal proceedings. Setting aside the previous judgments, the Court awarded a total compensation of Rs. 14,90,000 to the legal representatives of the deceased claimant, along with 6% interest from the date of filing the claim. The Court reminded the adjudicatory bodies to remain sensitive to the practical realities of accident victims who are seldom in a position to provide perfect proof while undergoing treatment.

Date of Decision: May 25, 2026