Strict Proof Not Required in Accident Claims; Preponderance of Probability Is Sufficient: Supreme Court

In a latest judgement, Supreme Court upheld a compensation award of ₹6,77,164 for the family of a motor accident victim. The Court dismissed ICICI Lombard's appeal against the findings of the Motor Accidents Claims Tribunal (MACT) and the Orissa High Court, emphasizing that negligence in motor accident claims must be assessed on the "preponderance of probabilities" and rejecting allegations of fraudulent police reports.

The case arose from a motor accident on April 27, 2019, in which Udayanath Sahoo lost his life when a truck rear-ended his motorcycle, causing him to crash into a tree. The deceased's family filed a claim under Section 166 of the Motor Vehicles Act, seeking compensation. Police investigations concluded that the accident was caused by the rash and negligent driving of the truck driver, leading to the filing of a chargesheet.

The MACT awarded ₹6,77,164 in compensation, holding the truck’s insurer, ICICI Lombard, liable. The Orissa High Court affirmed the Tribunal's decision. ICICI Lombard challenged these findings before the Supreme Court, alleging that the accident occurred solely due to the deceased's negligence and claiming collusion between the claimants and the police.

The Supreme Court reiterated that in motor accident claims, the standard of proof is not "beyond reasonable doubt" but "preponderance of probabilities." Referring to Mangla Ram v. Oriental Insurance Co. Ltd. (2018) and Mathew Alexander v. Mohammed Shafi (2010), the Court emphasized that strict proof of negligence is not required in such cases. It observed that the chargesheet naming the truck driver supported the finding of negligence.

The Court rejected the appellant’s argument that the Tribunal and High Court had erroneously relied on police records, such as the FIR and chargesheet. It held that these documents, when corroborated by other evidence, are valid sources for determining negligence in motor accident claims. The Court found no reason to doubt the credibility of the chargesheet, which had led to the truck driver being found guilty of rash and negligent driving.

ICICI Lombard alleged that the police colluded with the claimants to fraudulently prepare the chargesheet. The Court dismissed this contention, noting that the appellant failed to produce any evidence to substantiate the allegations. It underscored that unsubstantiated claims of fraud cannot undermine the Tribunal's findings based on credible evidence.

The Court highlighted that both the Tribunal and the High Court had independently evaluated the evidence, including eyewitness testimony and police records, and arrived at the same conclusion regarding the truck driver’s negligence. It observed that there was no perversity or illegality in these findings, warranting interference by the Supreme Court.

The Supreme Court dismissed the appeal, affirming the compensation awarded by the MACT and upheld by the High Court. It held that the Tribunal correctly applied the standard of preponderance of probabilities and found no merit in the insurer's allegations of fraud or negligence on the part of the deceased.

Date of Decision: January 2, 2025