Liability Under Motor Vehicles Act Must Be Established Through Credible Evidence: Supreme Court Upholds Claim Dismissal

The Apex Court was considering appeals challenging the impugned judgment passed by the Karnataka High Court, which dismissed the appeals preferred by the appellants, the legal representatives of both the deceased. The High Court had affirmed the order passed by the Motor Accident Claims Tribunal that dismissed the claim petitions filed by the present appellants.

The Division Bench of Justice Sanjay Karol and Justice Prashant Kumar Mishra held, “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, the principles of law cannot be set aside on the grounds of sympathy alone. Liability under the Motor Vehicles Act must be established through credible evidence. The Courts below have found, after scrutinizing the evidence, that the appellants failed to prove the involvement of the offending vehicle driven by respondent No.1. We find no perversity in the appreciation of evidence, nor exceptional circumstances warranting interference with these concurrent findings.”

Factual Background

The incident dates back to the year 2013, when Sunil Singh and his friend, Shivu, were returning on their motorcycle when a canter lorry, allegedly being driven in a rash and negligent manner, dashed against their motorcycle. This led to the death of Shivu on the spot, and Sunil subsequently succumbed to his injuries in the hospital. The legal representatives of both the deceased filed two separate claim petitions before the Tribunal. The Tribunal dismissed both the claim petitions. Aggrieved thereby, the legal representatives/appellants preferred their respective appeals before the High Court, which were also dismissed with the finding that the appellants had failed to prove the involvement of the offending vehicle in the alleged accident.

Reasoning

The Bench made it clear that the findings recorded by the Tribunal and affirmed by the High Court were concurrent findings of fact. The Bench noted that the Tribunal, after meticulously examining the evidence, identified serious infirmities and material contradictions in the testimonies of the witnesses. The Tribunal recorded that the first witness, who is the second appellant in the first appeal, presented a self-contradictory testimony. He claimed on one hand to have learnt about the accident from the Police, while on the other, he stated that he came to know about it from the witnesses. He admitted in cross-examination that he was a complete stranger to the alleged witnesses to the incident. He further admitted that neither he nor his children were present at the time of the accident and that he did not visit the spot.

The Bench noticed that the High Court, in the impugned judgment, observed that both, the first and second witnesses, being the star witnesses of the appellants, were unsure as to how the accident occurred and were equally unsure about the involvement of the alleged offending vehicle. “The Tribunal noted that both witnesses materially contradicted their examination-in-chief during cross-examination, with P.W.3 admitting he did not know who caused the accident and P.W.4 admitting he did not know which vehicle was involved. We find that these findings of fact are based on proper appreciation of evidence and do not suffer from any perversity”, it added.

The Bench noted that the omission of the vehicle registration number in the complaint could not be viewed in isolation, but in conjunction with other infirmities in the evidence. The complaint merely stated that a vehicular accident occurred without identifying the offending vehicle. The spot mahazar was admittedly prepared several days after the accident. In the absence of any eyewitness to the accident, the Bench held that there was nothing to indicate the basis upon which it was drawn up or whose statement formed its foundation.

“This Court is conscious of the settled legal position that in cases of motor vehicle accidents, the standard of proof required is that of preponderance of probabilities. It is also well settled that the absence of vehicle registration number in the FIR or complaint lodged immediately after the accident is not, by itself, fatal to the claim. An FIR is not an encyclopedia and omissions at the initial stage may not be determinative. However, the claimants must establish the specific identity of the vehicle/driver, with the caveat that the connection of the accident with the said vehicle must be established through cogent and reliable evidence”, the order read.

Referring to the report of the Motor Vehicle Inspector, the Bench stated that the same revealed no damage whatsoever to the alleged offending vehicle. This report provided no basis for the claim, and the fact that the chargesheet filed after the vehicle was recovered one and a half months post-accident raised concerns about the reliability of the evidence. The Bench also took note of the failure to prove the involvement of the offending vehicle.

Thus, in light of such facts and circumstances, the Bench dismissed the appeal.

Cause Title: Sithara N.S. & Ors. v. Sai Ram General Insurance Company Limited (Neutral Citation: 2025 INSC 1425)

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