In a significant judgment delivered on January 2, 2025, the Supreme Court of India elaborated on the application of the “preponderance of probabilities” standard in motor accident compensation cases. The bench, comprising Justice C.T. Ravikumar and Justice Rajesh Bindal, dismissed an appeal by ICICI Lombard General Insurance Co. Ltd., upholding the compensation awarded to the family of a deceased accident victim.
Case Background
The case stemmed from a fatal accident on April 27, 2009, where Udayanath Sahoo was killed after his motorcycle was struck from behind by a truck. The collision led the motorcycle to crash into a tree, resulting in Sahoo’s death and severe injuries to his pillion rider. Sahoo’s legal heirs filed a claim under Section 166 of the Motor Vehicles Act, 1988, seeking compensation of ₹10.5 lakh. The Motor Accidents Claims Tribunal (MACT), Nayagarh, awarded ₹6.77 lakh with 7% interest per annum.
The appellant insurer challenged the award, arguing that the accident occurred due to the deceased’s negligence. The High Court of Orissa dismissed the appeal, affirming the tribunal’s findings. The matter was then brought before the Supreme Court.
Key Legal Issues
1. Standard of Proof in Negligence Claims: The insurer contended that the tribunal improperly relied on police documents, including the FIR and chargesheet, to establish negligence.
2. Admissibility of Police Reports: The appellant alleged that these documents were fraudulent and influenced by the claimants.
3. Assessment of Negligence: The question arose whether the tribunal had appropriately determined negligence based on available evidence.
Observations of the Court
The Supreme Court emphasized that motor accident claims are decided on the principle of “preponderance of probabilities,” a civil standard of proof requiring the claimants to demonstrate that their version of events is more likely than not.
Citing previous judgments, including Mangla Ram v. Oriental Insurance Co. Ltd. and Dulcina Fernandes v. Joaquim Xavier Cruz, the bench stated:
“Strict proof of an accident caused by a particular vehicle in a particular manner need not be established by the claimants. A holistic view of the evidence must be taken into account, and the standard of proof beyond reasonable doubt does not apply in motor accident cases.”
The court rejected the insurer’s claims of fraud, observing that there was no substantial evidence to challenge the findings of the tribunal or the High Court. It noted that police documents, including the FIR and chargesheet, indicated that the truck driver was culpable for rash and negligent driving.
Decision
The Supreme Court upheld the compensation awarded to the victim’s family, ruling that the findings of both the tribunal and the High Court were supported by evidence. The bench remarked:
“In the context of motor accident claims, police reports and investigative findings serve as legitimate evidence when considered alongside other materials. There is no bar to their admissibility in determining negligence under the Motor Vehicles Act.”
The appeal by ICICI Lombard General Insurance Co. Ltd. was dismissed, reaffirming the lower courts’ conclusions.
Case Details
– Case Title: ICICI Lombard General Insurance Co. Ltd. vs. Rajani Sahoo & Ors.
– Case No.: Civil Appeal No. 29302 of 2019
– Bench: Justice C.T. Ravikumar and Justice Rajesh Bindal
