Supreme Court overturns High Court ruling in Motor Accident Claim: Sajeena Ikhbal & Ors. vs. Mini Babu George & Ors. (2024)

Date of the Judgment: 17 October 2024

Citation: 2024 INSC 787

Judges: C.T. Ravikumar, J. and Prashant Kumar Mishra, J.

Can a court dismiss a motor accident claim solely based on the absence of a witness statement in the police report, despite other evidence suggesting the involvement of a vehicle? The Supreme Court of India recently addressed this critical question in a case concerning a fatal road accident, where the High Court had dismissed a claim due to lack of conclusive proof of a car’s involvement. This judgment highlights the importance of considering all available evidence and applying the principle of preponderance of probabilities in motor accident claims. The bench comprised Justices C.T. Ravikumar and Prashant Kumar Mishra, with the judgment authored by Justice Prashant Kumar Mishra.

Case Background

On June 10, 2013, Ikhbal was riding his motorcycle from Thodupuzha to Muttom when he was fatally injured in an accident. The appellants, including Ikhbal’s widow, minor child, and parents, filed a claim petition alleging that a car, driven by respondent no. 2 and owned by respondent no. 1, had negligently hit Ikhbal’s motorcycle. The accident occurred near the ‘Mrala’ junction when Ikhbal was attempting to overtake a stopped K.S.R.T.C. bus. The respondents contested the claim, arguing that the accident was solely due to Ikhbal’s negligence and that the car was not involved. The Motor Accident Claims Tribunal (MACT) initially assessed the compensation at Rs. 46,31,496 but dismissed the claim, finding no proof of the car’s involvement. The High Court of Kerala affirmed this decision, leading to the present appeal before the Supreme Court.

Timeline

Course of Proceedings

The Motor Accident Claims Tribunal (MACT) initially assessed the compensation at Rs. 46,31,496 but dismissed the claim, stating that the appellants failed to prove that the accident occurred due to the negligent driving of the car driver, and that the car was involved in the accident. The High Court of Kerala upheld this decision, leading the appellants to file an appeal before the Supreme Court.

Legal Framework

The case primarily revolves around the principles of negligence and the burden of proof in motor accident claims. The Supreme Court considered the principle of “preponderance of probability,” which is used in civil cases, as opposed to the “proof beyond reasonable doubt” standard used in criminal cases. The Court also examined the relevance of police investigation reports and witness testimonies in determining the cause of an accident.

Arguments

Appellants’ Arguments:

• The appellants argued that there was sufficient evidence to demonstrate the car’s involvement in the accident.
• They contended that the MACT and the High Court had misread the evidence and made findings based on conjectures and surmises.
• The appellants emphasized that the statements of witnesses should be considered in conjunction with the principle of res ipsa loquitur (the thing speaks for itself).
• They sought to have the compensation assessed by the MACT awarded to them.

Respondents’ Arguments:

• The respondents argued that the courts below had correctly held that the car was not involved in the accident.
• They pointed out that none of the witnesses had directly seen the car hitting the motorcycle.
• They maintained that the findings of the lower courts were based on a careful examination of the evidence and did not warrant interference by the Supreme Court.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was:

1. Whether the High Court was correct in dismissing the claim petition by holding that the car was not involved in the accident.

Treatment of the Issue by the Court

Authorities

The Supreme Court relied on the following authority:

Judgment

How each authority was viewed by the Court?

• The Supreme Court relied on Mangla Ram v. Oriental Insurance Co. Ltd. & Ors. [(2018) 5 SCC 656] to justify its examination of the evidence, stating that it has the power to correct perverse findings or errors apparent on the record, even in appeals under Article 136 of the Constitution of India.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the following factors:

• The presence of damages to the car, as recorded in the Mahazar, which could not have occurred if the car was not involved in the accident.
• The testimony of PW-6, an eyewitness, who clearly stated that the car hit the motorcycle.
• The admission of the car driver (RW-2) that the bus was 100 feet away when the motorcycle hit the car.
• The principle of preponderance of probability, which requires the court to consider which version of events is more likely, rather than demanding proof beyond a reasonable doubt.
• The fact that the lower courts had disregarded key evidence and witness testimonies.

The Court’s reasoning was based on a careful analysis of the factual evidence presented, including the damages to the car, the eyewitness account, and the car driver’s admission. The legal principle of preponderance of probability was also a significant factor in the Court’s decision. The Court emphasized that the evidence, when viewed in its totality, pointed towards the car’s involvement in the accident.

The Supreme Court overturned the High Court’s decision, stating:

“In the light of the evidence on record, we set aside the finding of the courts below that the car was not involved in the accident, resultantly, holding that the deceased died as a result of accident involving the car insured with respondent no. 3.”

The Court also noted that:

“In claim cases, arising out of motor accident, the court has to apply the principles of preponderance of probability and cannot apply the test of proof beyond reasonable doubt.”

The Court further emphasized:

“The evidence available in the present case tested on the principles of preponderance of probability can record only one finding that the car was involved in the accident, otherwise, the damage found to the car in the Mahazar (Annexure P-2) was not possible.”

Key Takeaways

• In motor accident claims, courts must apply the principle of “preponderance of probability,” not “proof beyond reasonable doubt.”
• Witness testimonies should not be disregarded solely because they were not recorded by the police during the investigation.
• Material evidence, such as the damage to vehicles, is crucial in determining the cause of an accident.
• Lower courts’ findings can be overturned if they are based on misreading of evidence or conjectures.

Directions

The Supreme Court directed that the appellants be awarded compensation of Rs. 46,31,496 with interest at 9% per annum from the date of filing the claim petition until realization of the payment. The payment was to be made within three months, failing which the award amount would carry interest at 12% per annum.

Development of Law

The ratio decidendi of this case is that in motor accident claims, the principle of “preponderance of probability” must be applied, and courts should not dismiss claims solely based on the absence of a witness statement in the police report, especially when other evidence suggests the involvement of a vehicle. This judgment reinforces the need for a comprehensive evaluation of all available evidence in such cases. This case clarifies that the courts must consider all available evidence and apply the principle of preponderance of probability in motor accident claims. It emphasizes that the absence of a police statement from a witness is not sufficient grounds to disbelieve their testimony.

Conclusion

The Supreme Court allowed the appeal, setting aside the judgments of the High Court and the MACT. The Court held that the car was indeed involved in the accident and awarded compensation to the appellants. This judgment underscores the importance of a thorough evaluation of evidence in motor accident claims and the application of the principle of preponderance of probability.