Supreme Court Sets Aside High Court's Quashing of Final Report in Car Accident Case

In a recent decision, the Supreme Court of India has overturned the quashing of a final report in a car accident case by the High Court. The case involved a car accident that resulted in multiple deaths, and the final report had concluded that the accident was unavoidable and not due to negligence on the part of the deceased. The High Court had quashed the report, attributing negligence to the deceased.

In its judgement, the Supreme Court criticized the High Court's approach, stating, "The opinions expressed which are in the nature of findings while considering the correctness or otherwise of the final report submitted on further investigation of the case and thereby quashing the same is, in our view, not a correct and proper approach adopted by the High Court."

The Supreme Court further clarified that the quashing of the report would not impact the criminal proceeding as it had already abated due to the death of the accused. However, the Court emphasized that in the pending compensation claim petitions, the burden of proving negligence lies on the claimants, and it should be established based on preponderance of possibilities, not proof beyond reasonable doubt.

"It is for the Appellant herein to establish negligence on the part of the driver of the tanker lorry in the petition filed by him seeking compensation on account of the death of his son in the said accident," the judgement stated.

The Court also referred to previous cases, highlighting that in compensation claim petitions, the standard of proof beyond reasonable doubt does not apply, and the claimants must establish their case based on preponderance of probabilities.

Supreme Court set aside the High Court's order and allowed the appeal. The opinion in the final report was deemed to have no bearing on the compensation claim petitions. Each party was directed to bear their respective costs.

This judgement provides clarity on the burden of proof in compensation claim petitions arising from car accidents and emphasizes the need for a holistic evaluation of evidence to determine negligence.                                                             

Date of Decision: July 13, 2023

Mathew Alexander  vs Mohammed Shafi and Anr.