In Meera Bai & Ors. vs ICICI Lombard General Insurance Company Ltd. & Anr., the Supreme Court on April 30, 2025, set aside a High Court judgment that dismissed a motor accident compensation claim due to lack of eyewitness testimony. The Bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran restored the Motor Accident Claims Tribunal’s award, holding that an FIR and chargesheet against the driver sufficed to establish negligence.
Background of the Case:
The case arose from a motor accident on 29 January 2015 in which the deceased, travelling as a pillion rider on a motorbike owned and driven by the second respondent, suffered fatal injuries. The claimants—family members of the deceased—had filed a claim petition before the Motor Accident Claims Tribunal seeking compensation.
The Tribunal had found in favour of the claimants, but this decision was overturned by the High Court. The High Court accepted the insurance company’s appeal and dismissed the claim petition solely on the ground that no eyewitness had been examined to establish rash and negligent driving by the motorbike driver.
Arguments and Proceedings:
While the owner-driver denied any negligence in his written statement before the Tribunal, he did not enter the witness box to depose and support this denial. The FIR filed immediately after the accident accused him of rash and negligent driving, and a chargesheet was also filed against him.
Supreme Court’s Analysis:
The Supreme Court disagreed with the High Court’s approach, emphasising that in all motor accident claims, it is not always possible to examine an eyewitness. The Court noted:
“As far as examining the eyewitness, such a witness will not be available in all cases. The FIR having been lodged and the charge sheet filed against the owner driver of the offending vehicle, we are of the opinion that there could be no finding that negligence was not established.”
Accordingly, the Court found the High Court erred in setting aside the Tribunal’s award merely due to lack of direct eyewitness testimony.
Decision:
The Supreme Court allowed the appeal, stating:
“We are of the opinion that the order of the High Court must be set aside and that of the Tribunal restored.”
The Court clarified that it was not revisiting the quantum of compensation, as no appeal had been filed by the claimants on that issue. The Bench directed the insurance company to pay the compensation amount as determined by the Tribunal, along with interest at 7% per annum from the date of presentation of the claim petition.
All pending applications in the matter were also disposed of.
