Supreme Court Affirms Dismissal Of Motor-Accident Claims, Holds Concurrent Findings Of Fact Not Perverse

A bench of Justices Sanjay Karol and Prashant Kumar Mishra heard appeals arising from two claim petitions under Section 166 of the Motor Vehicles Act, challenging a judgment of the High Court of Karnataka which had affirmed the Motor Accident Claims Tribunal's dismissal of compensation claims arising out of a 2013 road accident that caused two deaths.

The Court dismissed the appeals and affirmed the concurrent findings of the Tribunal and High Court that the appellants had failed to prove the involvement of the alleged offending vehicle and rash or negligent driving. The Court reiterated that interference with concurrent findings of fact is permissible only in exceptional cases and not as a matter of course, noting that the appellants' evidence suffered from material contradictions and infirmities, and that some documentary evidence did not support the claim. The Court, in its reasoning, observed: "This Court is conscious of the settled legal position that in cases of motor vehicle accidents, the standard of proof required is that of preponderance of probabilities. It is also well settled that the absence of vehicle registration number in the FIR or complaint lodged immediately after the accident is not, by itself, fatal to the claim. An FIR is not an encyclopedia and omissions at the initial stage may not be determinative. However, the claimants must establish the specific identity of the vehicle/driver, with the caveat that the connection of the accident with the said vehicle must be established through cogent and reliable evidence." The Court also relied on the principle that "Jurisdiction under Article 136 of the Constitution of India is extraordinary and interference with the concurrent findings of fact recorded by the courts below is permissible only in exceptional cases and not as a matter of course." The Court observed that "the principles of law cannot be set aside on the grounds of sympathy alone."

Background

On the night of 14 August 2013, Sunil Singh (26) and his friend Shivu (22) were returning on a motorcycle near Sugur village when, according to the claimants, an alleged canter lorry struck their vehicle, resulting in Shivu's death on the spot and Sunil's subsequent death in hospital. Legal representatives of each deceased filed separate claim petitions (M.V.C. Nos.1155/2013 and 1156/2013) before the Tribunal. The Tribunal dismissed both petitions after finding contradictions in the eyewitness testimony and deficiencies in the evidence; the High Court at Bengaluru dismissed the appeals, and the matter reached this Court by way of special leave.

The appellants relied on the FIR (No.277/2013), post-mortem reports, a chargesheet filed against the driver, spot mahazars, recovery panchanamas and oral testimony of witnesses (P.W.1–P.W.4). The insurer contended that the claimants failed to establish three essentials under Section 166: occurrence of the accident, involvement of the specific vehicle, and rash/negligent driving by that vehicle. The Tribunal and High Court found that the star witnesses were uncertain and contradictory about the manner of the accident and the identity of the offending vehicle. The Motor Vehicle Inspector's report dated 05.10.2013 showed no damage to the recovered vehicle, and the chargesheet was filed only after the vehicle was recovered about one-and-a-half months later — factors the Court treated as weakening the causal link.

The Court analysed evidence appreciation standards and applied settled precedent that concurrent findings attract interference only if the appreciation was wholly unsatisfactory or perverse. Finding no such perversity and noting cogency defects in both oral and documentary evidence, the Court dismissed the appeals for lack of merit and declined to interfere. No costs were ordered and no interim directions were recorded.

Case Details: Case No.: 2025 INSC 1425 (Civil Appeal Nos. 14718-14719 of 2025; arising out of S.L.P. (C) Nos. 281-282/2019) Case Title: SITHARA N.S. & ORS. ETC. v. SAI RAM GENERAL INSURANCE COMPANY LIMITED Appearances: For the Petitioner(s): [Advocates not indicated in the judgment] For the Respondent(s): [Advocates not indicated in the judgment]