The Gauhati High Court reaffirms that Motor Accident Claims Tribunals must consider exhibited Income-Tax Returns (ITRs) in assessing the income of a deceased for compensation purposes, following Supreme Court precedent. Where evidence is ambiguous, the matter can be remanded for limited verification. This case underscores the requirement for Tribunals in motor accident matters to treat ITRs as reliable statutory documents unless proven otherwise, and constitutes binding authority for lower courts in similar compensation assessments.
Summary
| Category | Data |
|---|---|
| Case Name | MACApp./377/2018 of SMTI PAYARI DEVI and 4 ORS Vs SRI MANOJ KUMAR JAIN and ANR |
| CNR | GAHC010169602017 |
| Date of Registration | 14-05-2018 |
| Decision Date | 03-11-2025 |
| Disposal Nature | Disposed Of |
| Judgment Author | HONOURABLE MR. JUSTICE KAUSHIK GOSWAMI |
| Court | Gauhati High Court |
| Bench | Single Judge (HONOURABLE MR. JUSTICE KAUSHIK GOSWAMI) |
| Precedent Value | Binding on subordinate courts |
| Overrules / Affirms | Affirms Supreme Court precedents; clarifies application at the Tribunal level |
| Type of Law | Motor Vehicle Accident Claims; Law of Evidence |
| Questions of Law | Whether Motor Accident Claims Tribunals are bound to consider exhibited Income-Tax Returns in assessing the income of the deceased. |
| Ratio Decidendi |
The Court held that ITRs are statutory documents presumed correct unless rebutted, and Tribunals must consider them in compensation cases. The rejection of a salary certificate for lack of proof does not justify ignoring ITRs. Where the ITRs are ambiguous or their calculation is unclear, the case may be remanded for limited verification to determine correct income. The remand is strictly for assessing income based on ITRs, with other findings left undisturbed. |
| Judgments Relied Upon |
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| Logic / Jurisprudence / Authorities Relied Upon by the Court |
ITRs, as entries in public/statutory records, have a presumption of correctness under Section 35 of the Evidence Act. Strict rules of evidence are relaxed in summary Tribunals. Previous Supreme Court rulings direct reliance upon ITRs, where reasonably available, for income assessment in accident compensation cases. |
| Facts as Summarised by the Court |
The deceased, Karan Singh, died in a road accident in 2012. The claimant presented both a salary certificate and ITRs showing the deceased was an assessee. The Tribunal rejected the salary certificate and ignored ITRs, assessing income notionally. Appeal sought enhancement based on the ITRs; Insurance Company conceded ITRs were ignored at Tribunal level. The Court remanded the matter to the Tribunal for limited verification of income using ITRs and additional evidence. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and Motor Accident Claims Tribunals within the territory of the Gauhati High Court |
| Persuasive For | Other High Courts and Tribunals in India handling motor accident claims where ITRs are presented as income proof |
| Follows |
|
What’s New / What Lawyers Should Note
- Reaffirms that Income-Tax Returns (ITRs) must be considered by Motor Accident Claims Tribunals when exhibited by the claimants.
- Salary certificates, if rejected for lack of proof, do not nullify the probative value of ITRs as statutory documents.
- If ITRs are ambiguous or do not clearly specify gross income, limited remand for verification—including calling for clarification from the Income Tax Department—is permissible.
- The remand is strictly limited to income determination; all other findings of the Tribunal remain undisturbed.
- Lawyers should always exhibit available ITRs in accident claim proceedings and be prepared to seek remand if Tribunals fail to consider them.
Summary of Legal Reasoning
- The Court outlined the primary issues: Whether the Tribunal erred in ignoring exhibited ITRs and whether income should be reassessed by the appellate court or remanded for verification.
- It relied on Supreme Court precedents (Sunil Sharma, Malarvizhi, Sangita Arya, Oriental Insurance v. Deo Patodi, Laxmidevamma) that underscore ITRs as statutory documents presumed correct unless rebutted.
- The Court noted that tribunals, as summary forums, are not bound by strict evidentiary standards. ITRs carry a presumption of correctness, and their probative value is recognized unless shown to be fabricated.
- The Tribunal’s omission to consider ITRs was found to be a material error. Dismissing a salary certificate without evaluating ITRs is contrary to law.
- Because the ITRs on record were ambiguous and did not clearly establish gross income, the Court declined to undertake income reassessment itself.
- Instead, it remanded the matter for limited verification of the income, instructing the Tribunal to consider ITRs, seek clarifications from tax authorities if required, and allow for additional evidence on income.
- Other findings of the Tribunal, including liability and interest rate, were left undisturbed, with directions to recalculate compensation afresh based on verified income.
Arguments by the Parties
Petitioner
- The Tribunal erred by failing to consider the ITRs, which the claimants exhibited and which established the deceased’s income.
- Rejection of the salary certificate should not have led to notional income assessment when ITRs were available.
- The proper multiplier based on the age of the deceased, and not of his mother, should be applied.
- Sought enhancement of compensation, and for interest to be granted from the claim petition’s filing date.
Respondent No. 2 (Insurance Company)
- Conceded that the Tribunal did not consider the exhibited ITRs in its income assessment.
- Agreed that interest is ordinarily to run from the claim filing date.
- Submitted that the interest rate fixed by the Tribunal was fair and reasonable, and should stand.
Respondent No. 1 (Owner/Driver)
- Informed that the issue of driving licence validity had been considered pursuant to a remand in related proceedings, and is not under dispute.
Factual Background
The deceased, Karan Singh, died in a road traffic accident on 27.10.2012. His family filed a compensation claim before the Motor Accident Claims Tribunal. The claimants produced both a salary certificate and Income-Tax Returns (ITRs) to evidence the deceased’s income. The Tribunal rejected the salary certificate for want of proof and did not discuss the ITRs, instead assessing the monthly income notionally at Rs. 4,500/-. The claimants appealed, seeking enhancement on the basis that the ITRs were reliable statutory proof of actual income. The Insurance Company conceded the Tribunal had ignored the ITRs. The High Court remanded the matter to the Tribunal for limited verification and reassessment of income.
Statutory Analysis
- Section 35 of the Indian Evidence Act: ITRs, as entries in public records made by a public servant, are presumed to be genuine and can be relied upon as statutory documents unless proved otherwise.
- No strict rule of evidence applies; Motor Accident Claims Tribunals operate as summary forums and may rely on such documents unless rebutted.
- The Court followed Supreme Court guidance that income proof through ITRs is sufficient unless impugned as fabricated.
- Multiplier principles and compensation methodology to be in accordance with Sarla Verma v. DTC (2009) 6 SCC 121 and National Insurance Co. Ltd. v. Pranay Sethi & Ors. (2017) 16 SCC 680.
Procedural Innovations
- The Court directed a limited remand to the Tribunal solely on the issue of income, instructing that both parties may lead additional oral or documentary evidence, confined only to income determination.
- The Tribunal was directed to call for clarifications from the Income Tax Department if necessary, ensuring thorough verification of the entries in the ITRs.
- Directions given to complete the process within a stipulated three-month period from appearance.
Alert Indicators
- ✔ Precedent Followed – The Court has followed and reaffirmed established Supreme Court rulings regarding the evidentiary weight accorded to Income-Tax Returns in accident claims, and has clarified their mandatory consideration by tribunals.