The High Court of Chhattisgarh reaffirmed that an insurance company, to escape liability for compensation under the Motor Vehicles Act, must adduce concrete evidence and cannot rely solely on allegations of false implication. This judgment upholds settled precedent, reinforcing that insurers bear the burden of proof if disputing liability, and serves as binding authority for all subordinate courts hearing similar claims.
Summary
| Category | Data |
|---|---|
| Case Name | MAC/1026/2023 of TATA A.I.G. GENERAL INSURANCE COMPANY LIMITED Vs MANKUNWAR MARABI |
| CNR | CGHC010205302023 |
| Date of Registration | 28-06-2023 |
| Decision Date | 30-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE SHRI JUSTICE SANJAY K. AGRAWAL |
| Court | High Court Of Chhattisgarh |
| Bench | Single Bench (Justice Sanjay K. Agrawal) |
| Precedent Value | Binding on subordinate courts in Chhattisgarh |
| Overrules / Affirms | Affirms the award of the Additional Motor Accident Claims Tribunal, Pratappur, District Surajpur |
| Type of Law | Motor Accident Claims / Insurance Law |
| Questions of Law | Whether an insurance company can be exonerated from liability to pay compensation solely by alleging false implication of driver and vehicle, without adducing supporting evidence. |
| Ratio Decidendi | To avoid liability for compensation under the Motor Vehicles Act, an insurance company must provide substantive evidence if it alleges false implication of the driver and offending vehicle. Mere plea, without corroborative proof, is insufficient. The tribunal’s fastening of liability on the insurer is correct in absence of contrary evidence. |
| Facts as Summarised by the Court | The appellant/insurance company argued that the driver and offending vehicle were falsely implicated in the accident but did not produce any evidence in support. The Tribunal had awarded compensation to the claimants, holding the insurance company liable. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh dealing with motor accident claim appeals |
| Persuasive For | Other High Courts and Tribunals considering similar questions under the Motor Vehicles Act |
| Overrules | None indicated in the judgment |
| Distinguishes | None indicated in the judgment |
| Follows | Tribunal’s findings in MAC Case No. 79/2019, Additional Motor Accident Claims Tribunal, Pratappur |
What’s New / What Lawyers Should Note
- Reaffirms that insurance companies cannot rely on mere allegations of false implication; absence of supporting evidence is fatal to their defence.
- Restates the evidentiary burden on the insurer challenging liability under Motor Vehicles Act claims.
- Advocates must advise insurer clients to marshal and present clear evidence if their defence is based on false implication of driver or vehicle.
- This precedent can be cited by claimants to counter bare denials by insurers in compensation appeals.
Summary of Legal Reasoning
- The Court considered submissions from both parties: the insurance company contended the driver and vehicle were falsely implicated, while the claimants/respondents supported the tribunal’s finding.
- The record showed that the insurance company advanced only a plea of false implication without adducing any evidence to substantiate its claim.
- The High Court held that in the absence of evidence, the tribunal’s fastening liability upon the insurance company was justified.
- The Court found no merit in the insurer’s appeal and affirmed the tribunal’s award.
- Thus, the High Court dismissed the appeal, holding that mere allegations, unsupported by proof, cannot absolve the insurer from liability.
Arguments by the Parties
Petitioner (Insurance Company):
- Asserted that the driver and the offending vehicle were falsely implicated in the accident.
- Contended that the findings of the Claims Tribunal were perverse and sought exoneration from liability.
Respondent (Claimants):
- Supported the tribunal’s impugned award.
- Submitted that liability was correctly fastened upon the insurance company.
Factual Background
The insurance company appealed the award of the Additional Motor Accident Claims Tribunal, Pratappur, which had directed it to pay compensation to claimants for a fatal road accident. In its defence, the insurer alleged that the driver and the vehicle had been falsely implicated, but produced no evidence in support. The Tribunal had awarded compensation of Rs.9,97,200/- with interest, holding the insurer liable.
Statutory Analysis
The judgment considers Section 173 of the Motor Vehicles Act, 1988, dealing with appeals from the Motor Accident Claims Tribunal. The judgment reiterates the principle that an insurer seeking exoneration from liability bears the burden of proof and cannot discharge it merely by making unsubstantiated allegations.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are recorded in the judgment.
Procedural Innovations
No new procedural precedents or innovations are indicated in the judgment.
Alert Indicators
- ✔ Precedent Followed – The decision affirms existing law that evidence, not mere allegation, is required from an insurance company to dispute liability in motor accident claims.