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by Admin
15 December 2025 9:38 AM
“The pain of losing young lives is immeasurable, but sympathy cannot override the statutory requirement of credible evidence” – In a significant judgment that clarifies the legal standard in motor accident compensation claims, the Supreme Court of India upheld the dismissal of compensation petitions arising from a tragic road accident that claimed two young lives. The Court emphasized that mere occurrence of an accident is not enough to claim compensation under Section 166 of the Motor Vehicles Act, 1988, unless the involvement of the specific offending vehicle and the element of rash and negligent driving are clearly established by cogent and credible evidence.
A bench of Justices Sanjay Karol and Prashant Kumar Mishra delivered the judgment, rejecting the appeals filed by the legal heirs of the deceased, and affirmed the concurrent findings of both the Motor Accident Claims Tribunal, Shimoga, and the Karnataka High Court.
Supreme Court: “Preponderance of Probabilities Does Not Mean Absence of Proof”
Delivering the verdict, Justice Prashant Kumar Mishra, writing for the bench, made a crucial legal distinction:
“It is well settled that the standard of proof in motor vehicle accident claims is one of preponderance of probabilities. However, even this standard requires the claimants to adduce reliable and cogent evidence connecting the alleged accident to the specific vehicle and driver. Mere suspicion or hearsay is not enough.” [Para 16]
The Court held that although it was undisputed that an accident occurred on 14.08.2013 leading to the death of two individuals—Sunil Singh and Shivu—the appellants failed to establish that the Canter lorry bearing registration no. KA20-AA-6786, allegedly driven by Respondent No.1, was in fact involved in the incident.
“Hearsay Testimonies and Improbable Confession Render Witnesses Unreliable” – SC Rejects PW-3 and PW-4 Evidence
The Court carefully examined the testimonies of the witnesses produced by the claimants. It noted that:
“P.W.1 and P.W.2, the fathers of the deceased, were not eyewitnesses. Their accounts were based entirely on hearsay, with inconsistent statements about how they came to know of the accident.” [Paras 13–14]
Most notably, the apex court dismissed the reliability of P.W.3 and P.W.4, who claimed that the alleged driver of the lorry had voluntarily confessed to them and revealed the registration number of the vehicle.
The Court held this version to be “inherently improbable” and “contrary to normal human behaviour,” observing:
“Such a confession by the driver, without any prior relationship with the witnesses, is inconsistent with ordinary human conduct. Moreover, the witnesses materially contradicted themselves during cross-examination.” [Para 15]
Motor Vehicle Inspector’s Report: ‘No Damage to Vehicle’ Undermines Claim
One of the most damning pieces of evidence against the appellants was the Motor Vehicle Inspector’s report dated 05.10.2013, which found no damage whatsoever to the Canter lorry that was allegedly involved in the fatal accident.
The Court held:
“It is inconceivable that a collision of such magnitude, which caused the death of two persons, would leave the alleged offending vehicle completely undamaged. This is a strong circumstance that militates against the claim of the appellants.” [Para 18]
Additionally, the fact that the vehicle was recovered only one and a half months after the accident further cast doubt on its alleged involvement.
Chargesheet Alone Not Conclusive – Must Be Considered Alongside Other Evidence
The appellants had placed strong reliance on the FIR, chargesheet, and post-mortem reports to support their case. However, the Supreme Court reiterated that filing of a chargesheet does not, in itself, prove the involvement of the vehicle, particularly when the rest of the evidence is unreliable.
“The chargesheet is but one circumstance to be weighed in the overall matrix. In this case, the totality of the evidence, including the contradictions and absence of corroboration, does not support the appellants’ case.” [Paras 9–10, 18]
Concurrent Findings of Tribunal and High Court Upheld – No Perversity Found
Upholding the decisions of both the Tribunal and the High Court, the Supreme Court noted that the findings were based on a detailed appreciation of evidence, and that there was no perversity or error warranting interference under Article 136 of the Constitution.
Citing Collector Singh v. L.M.L. Ltd., (2015) 2 SCC 410, the Court held:
“This Court’s jurisdiction under Article 136 is extraordinary and is not to be exercised routinely, especially where there are concurrent findings of fact by the courts below. No exceptional circumstances have been shown here.” [Para 12]
Law Cannot Be Bent Even in Cases of Tragic Loss
In a poignant observation acknowledging the human tragedy involved, the Court stated:
“We are deeply conscious of the tragic loss suffered by the families of the deceased. The pain of losing young lives in their prime is immeasurable. However, principles of law cannot be set aside on the grounds of sympathy alone.” [Para 19]
Thus, the Court concluded that the appellants had failed to discharge the burden of proof required under Section 166 of the Motor Vehicles Act, which mandates that the claimants must establish:
The occurrence of the accident
Involvement of the specific vehicle, and
Rash and negligent act by the driver of that vehicle
Here, only the first ingredient was established.
The civil appeals were dismissed, with no order as to costs.
This judgment is a cautionary precedent in motor accident compensation law, reinforcing that empathy cannot override evidentiary requirements. Claimants must produce trustworthy and corroborated evidence connecting the accident to the specific vehicle. FIRs, chargesheets, and oral testimonies—if not adequately supported—are insufficient. Importantly, even in proceedings governed by preponderance of probabilities, hearsay and improbabilities will not suffice.
Date of Decision: 12th December 2025
