Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-014718-014719 – 2025 |
| Diary Number | 39706/2018 |
| Judge Name | HON’BLE MR. JUSTICE PRASHANT KUMAR MISHRA |
| Bench |
HON’BLE MR. JUSTICE PRASHANT KUMAR MISHRA HON’BLE MR. JUSTICE PRASANNA B. VARALE |
| Precedent Value | Reaffirms existing principles on Article 136 interference and proof under Section 166 MVA |
| Overrules / Affirms | Affirms concurrent findings of fact and the approach of lower courts |
| Type of Law | Motor Vehicles Act, 1988 (Section 166) |
| Questions of Law |
|
| Ratio Decidendi |
The Supreme Court held that concurrent findings of fact on vehicle involvement rendered by a Tribunal and affirmed by the High Court cannot be disturbed in absence of perversity or wholly unsatisfactory appreciation of evidence. In motor accident claims under Section 166, claimants must prove (i) occurrence, (ii) involvement of the vehicle, and (iii) rash or negligent driving on a preponderance of probabilities. Omission of registration number in the FIR is not fatal alone, but must be read with other infirmities—here the MVI report showed no damage, eyewitness testimonies were contradictory, and no cogent link was established between the offending vehicle and the accident. Under these circumstances, the claim petitions were rightly dismissed. |
| Judgments Relied Upon | Collector Singh v. L.M.L. Limited, Kanpur (2015) 2 SCC 410 (Para 9) |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court | On 14 August 2013, two young men riding a motorcycle were fatally struck at night near Sugur village by an alleged canter lorry. Separate Section 166 petitions were filed by their legal heirs. The Motor Accident Claims Tribunal dismissed both claims for failure to prove the offending vehicle’s involvement; the Karnataka High Court affirmed. The Supreme Court granted leave and confirmed that the appellants had not established the required link between vehicle and accident. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts when considering Section 166 claims and Article 136 interference standards |
| Follows | Collector Singh v. L.M.L. Limited, Kanpur (2015) |
What’s New / What Lawyers Should Note
- Concurrent factual findings on vehicle involvement will not be disturbed on appeal unless shown to be perverse or based on wholly unsatisfactory evidence.
- Claimants must establish all three elements under Section 166 (occurrence, involvement, rash/negligence) on a preponderance of probabilities.
- Omission of vehicle registration in the FIR is not fatal by itself but must be considered with other evidence gaps.
- A Motor Vehicle Inspector’s report showing no damage to the alleged offending vehicle can be decisive against a claim.
- Mere filing of a chargesheet does not conclusively establish vehicle involvement; it is one factor in the overall probabilistic assessment.
Summary of Legal Reasoning
- The Court noted that both the Tribunal and the High Court made concurrent findings on fact regarding vehicle involvement.
- Recalling Collector Singh, interference under Article 136 is limited to exceptional cases of perversity or wholly unsatisfactory evidence appreciation.
- Examination of eyewitness testimonies revealed material contradictions and admissions of ignorance about the vehicle’s involvement.
- The FIR did not name the vehicle; the spot mahazar was prepared days later without clear foundation.
- The Motor Vehicle Inspector’s report dated 05-10-2013 recorded no damage to the recovered lorry—antithetical to a fatal collision.
- As claimants failed to establish the second and third elements of Section 166, the concurrent dismissals were upheld.
Arguments by the Parties
Petitioner (Legal Representatives of the Deceased):
- The accident and deaths were proved by FIR No. 277/2013, post-mortem reports, chargesheet, spot mahazar, recovery panchnamas, and SW evidence (P.W.1–P.W.4).
- The courts below erred by applying a criminal standard and dismissing on technical grounds rather than on preponderance of probabilities.
Respondent (Sai Ram General Insurance Co. Ltd.):
- Section 166 claims require proof of occurrence, involvement of the vehicle, and rash/negligence; here only occurrence is established.
- The chargesheet alone cannot establish involvement; the MVI report shows no damage to the alleged offending vehicle.
- No cogent evidence links the recovered canter lorry to the accident.
Factual Background
On 14 August 2013, at around 11:30 p.m., Sunil Singh and Shivu were riding a motorcycle near Sugur village when a canter lorry allegedly driven rashly struck them. Shivu died on the spot; Sunil succumbed later in hospital. Their legal heirs filed separate claims under Section 166 MVA before MACT–VII, Shimoga, which dismissed both petitions for failure to prove the offending vehicle’s involvement. The Karnataka High Court upheld those dismissals, prompting these appeals.
Statutory Analysis
- Section 166, Motor Vehicles Act, 1988: entitlement to compensation requires proof of (i) accident occurrence, (ii) involvement of the specific motor vehicle, and (iii) rash/negligent driving.
- Standard of proof is preponderance of probabilities—less stringent than “beyond reasonable doubt.”
- FIR omissions (e.g., vehicle registration number) are not conclusive but form part of the probabilistic assessment.
- The Court emphasized careful scrutiny of police records, spot mahazars, MVI reports, and witness testimony to establish the statutory elements.
Alert Indicators
- ✔ Precedent Followed – Affirms existing law on Article 136 interference with concurrent findings and proof requirements under Section 166 MVA.