The Supreme Court of India has dismissed appeals filed by the legal representatives of two deceased accident victims, affirming the concurrent findings of the High Court of Karnataka and the Motor Accident Claims Tribunal. The Court held that while the standard of proof in motor accident cases is “preponderance of probabilities,” liability cannot be fastened on an insurer merely on the grounds of sympathy if the involvement of the offending vehicle is not established by credible evidence.
The Division Bench comprising Justice Sanjay Karol and Justice Prashant Kumar Mishra observed that the evidence produced by the appellants was contradictory and the alleged offending vehicle showed no signs of damage, which was inconsistent with the severity of the collision.
Background of the Case
The case stems from a road accident that occurred on August 14, 2013. The deceased, Sunil Singh (26) and his friend Shivu (22), were returning from Honnali on a motorcycle bearing Registration No. KA-14-ED-9828. Around 11:30 p.m., near Sugur village, they were allegedly hit by a canter lorry bearing Registration No. KA-20-AA-6786, which was reportedly being driven in a rash and negligent manner. Shivu died on the spot, and Sunil subsequently succumbed to his injuries in the hospital.
The legal representatives of the deceased filed two separate claim petitions (M.V.C Nos. 1155/2013 and 1156/2013) before the Motor Accident Claims Tribunal-VII, Shimoga. On April 30, 2015, the Tribunal dismissed both petitions. The claimants then approached the High Court of Karnataka, which also dismissed their appeals (MFA Nos. 5891/2015 and 5892/2015) vide judgment dated June 7, 2018, noting that they had failed to prove the involvement of the alleged offending vehicle.
Arguments of the Parties
The Appellants’ Submissions: Learned senior counsel for the appellants contended that the accident and the resultant deaths were proved on the “preponderance of probabilities.” Reliance was placed on FIR No. 277/2013, post-mortem reports, the chargesheet filed against the driver of the offending vehicle (Respondent No. 1), and the oral evidence of four witnesses (P.W.1 to P.W.4).
The appellants argued that the courts below erred in applying the standard of proof “beyond reasonable doubt” instead of “preponderance of probabilities” and wrongly rejected the claims on technical grounds. It was further submitted that the spot mahazar and recovery panchanamas conclusively established the rash and negligent driving, and that the driver and owner failed to lead any rebuttal evidence.
The Respondent’s Submissions: Counsel for Respondent No. 3, Sai Ram General Insurance Company Limited, argued that proving the involvement of the vehicle and the rash and negligent act is a sine qua non for the maintainability of a petition under Section 166 of the Motor Vehicles Act, 1988.
The insurer submitted that mere filing of a chargesheet should not be treated as “gospel truth.” They highlighted that the Motor Vehicle Inspector’s report dated October 5, 2013, did not support the appellants’ case and that apart from a chargesheet filed after the vehicle was recovered one and a half months post-accident, no evidence existed to show the vehicle’s involvement.
Court’s Analysis
The Supreme Court examined the concurrent findings of fact recorded by the Tribunal and the High Court. Referring to the precedent in Collector Singh vs. L.M.L. Limited, Kanpur (2015), the Bench reiterated that interference with concurrent findings under Article 136 of the Constitution is permissible only in “exceptional cases” where the appreciation of evidence is “wholly unsatisfactory or the conclusion drawn from the same is perverse in nature.”
Contradictory Testimonies: The Court noted that the Tribunal had identified material contradictions in the testimonies. P.W.1 (Parashuram Singh) and P.W.2 (Parmesh), the fathers of the deceased, admitted they were not present at the spot and their knowledge was based on hearsay.
Regarding the alleged eyewitnesses, P.W.3 (Lokesh) and P.W.4 (Ravi), the Court upheld the Tribunal’s view that their claim—that the driver voluntarily confessed to them—was “inherently improbable and contrary to normal human conduct.”
Crucial Evidence – The Motor Vehicle Report: The Court placed significant weight on the absence of damage to the alleged offending vehicle. Justice Mishra, writing for the Bench, observed:
“Most significantly, the report dated 05.10.2013 of the Motor Vehicle Inspector reveals no damage whatsoever to the alleged offending vehicle. A circumstance that is wholly inconsistent with a collision of such severity as to cause the death of two persons. This report provides no basis for the claim, and the fact that the chargesheet filed after the vehicle was recovered one and a half months post-accident raises concerns about the reliability of the evidence.”
Standard of Proof: While acknowledging that the standard of proof in such cases is preponderance of probabilities and that an FIR is not an encyclopedia, the Court held that claimants must still establish the specific identity of the vehicle through “cogent and reliable evidence.”
Decision
The Supreme Court dismissed the appeals, holding that the appellants failed to prove the involvement of the offending vehicle. The Court concluded:
“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.”
Case Details:
- Case Title: Sithara N.S. & Ors. Etc. vs. Sai Ram General Insurance Company Limited
- Case Number: Civil Appeal Nos. 14718-14719 of 2025 (Arising out of S.L.P. (C) Nos. 281-282/2019)
- Citation: 2025 INSC 1425
- Coram: Justice Sanjay Karol and Justice Prashant Kumar Mishra
