Supreme Court Upholds MACT Award in Motor Accident Claim Case: Geeta Dubey & Ors vs. United India Insurance Co. Ltd. & Ors. (2024) INSC 998 (18 December 2024)

Introduction

Date of the Judgment: 18 December 2024

Citation: (2024) INSC 998

Judges: B.R. Gavai, J. and K.V. Viswanathan, J.

Can a High Court overturn a detailed award by the Motor Accident Claims Tribunal (MACT) based on a summary assessment of evidence? The Supreme Court recently addressed this question in a case concerning a motor vehicle accident. The core issue was whether the claimants had sufficiently proven the involvement of a specific truck in the accident that led to the death of Chakradhar Dubey. The Supreme Court bench, consisting of Justice B.R. Gavai and Justice K.V. Viswanathan, delivered the judgment, with the opinion authored by Justice K.V. Viswanathan.

Case Background

On 18 June 2018, Chakradhar Dubey, an Assistant Post-Master, was traveling in a car driven by his friend Narayan Das Tiwari when their vehicle was hit by a truck. The accident occurred around 8:15 PM, one kilometer ahead of Sonwari Toll Plaza in Maihar. Chakradhar Dubey sustained severe injuries, including a broken spine, and was initially admitted to Civil Hospital, Maihar.

A First Information Report (FIR) was registered on 21 June 2018, at Maihar Police Station, initially against an unknown truck. The FIR mentioned the time, place, and injuries sustained by Chakradhar Dubey. Subsequently, Chakradhar Dubey was treated at Nagpur Arneja Institute of Cardiology Private Limited from 19 June 2018, but he passed away on 28 June 2018.

The claimant, Geeta Dubey, the widow of the deceased, stated that she was mentally unfit to gather information and file a claim immediately after the incident. Upon recovering, she collected information and discovered that the accident was caused by the rash and negligent driving of a truck bearing registration number MP-19-HA-1197, driven by respondent no. 2. She then informed the Superintendent of Police.

Initially, the police filed a closure report on 29 September 2018. However, after the claimant submitted an application stating that there were eyewitnesses, the investigation was reopened. Statements from witnesses, including Sonu Shukla, Janardan Paroha, Kapil Pandey, Praful Dubey, and Narayan Das Tiwari, were recorded. The charge sheet stated that the accident was caused by the driver of truck MP-19-HA-1197, and the vehicle was seized. A claim petition was filed seeking compensation of Rs. 59,30,000/-.

Timeline:

Course of Proceedings

The Motor Accident Claims Tribunal (MACT) allowed the claim of the appellants and awarded a compensation of Rs. 50,41,289/- against the respondents. The MACT relied on the eyewitness account and the fact that the insurance company did not dispute the accident or the death of the deceased, but only the involvement of the truck.

The insurance company appealed to the High Court of Madhya Pradesh, primarily contesting the involvement of the truck bearing registration no. MP-19-HA-1197 and arguing that the deceased was 58 years old, warranting a lower multiplier. The High Court, in a summary order, set aside the MACT award, stating that the claimants failed to provide sufficient evidence linking the truck to the accident and questioning the delay in pursuing the case.

Legal Framework

The case primarily involves the interpretation and application of the following legal provisions:

• Section 173 of the Motor Vehicles Act, 1988: This section deals with appeals against the awards of the Claims Tribunal. The Supreme Court noted that an appeal under this section is in the nature of a first appeal, requiring a careful marshalling of oral and documentary evidence.
• Section 106 of the Evidence Act, 1872: This section pertains to the burden of proof in cases where facts are especially within the knowledge of a party. The Supreme Court referred to this section in the context of the insurance company’s claim that the vehicle was wrongly implicated.

Arguments

Appellants’ Arguments (Claimants):

• ✓ The claimants argued that the accident occurred due to the rash and negligent driving of the truck bearing registration number MP-19-HA-1197, which hit the car in which the deceased was traveling.
• ✓ They contended that the FIR, though initially against an unknown vehicle, mentioned the date, time, and place of the accident, along with the injuries sustained by the deceased.
• ✓ The claimants submitted that the delay in identifying the truck was due to their mental distress following the accident and the subsequent death of Chakradhar Dubey.
• ✓ They highlighted the eyewitness testimony of Sonu Shukla (PW-2), who stated that he witnessed the truck hitting the car and also the subsequent police investigation and charge sheet which implicated the truck.
• ✓ The claimants emphasized that they had provided sufficient evidence to establish the involvement of the truck on the principle of preponderance of probability.

Respondents’ Arguments (Insurance Company):

• ✓ The insurance company argued that the claimants failed to provide sufficient evidence to prove that the truck bearing registration number MP-19-HA-1197 was involved in the accident.
• ✓ They questioned the delay in identifying the truck and the fact that the FIR was initially against an unknown vehicle.
• ✓ The insurance company contended that the claimants did not seek investigation for CCTV footage to prove the accident.
• ✓ They argued that the deceased was 58 years old, not 55 as claimed, and therefore, a lower multiplier should be applied for calculating compensation.
• ✓ The insurance company did not lead any cogent evidence of any eye witness.

Sub-Submissions Categorized by Main Submissions:

Issues Framed by the Supreme Court

The Supreme Court framed the following issue for consideration:

1. Was the High Court justified in setting aside the order of the MACT?

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court considered the following authorities:

On the nature of appeals under Section 173 of the Motor Vehicles Act, 1988:

• ✓ Sudarsan Puhan vs. Jayanta Ku. Mohanty and Others, (2018) 10 SCC 552, Supreme Court of India: The Court reiterated that an appeal under Section 173 is in the nature of a first appeal, requiring a comprehensive review of facts and law.
• ✓ Uttar Pradesh State Road Transport Corporation vs. Mamta and Others, (2016) 4 SCC 172, Supreme Court of India: This case was cited to emphasize the legal obligation of the High Court to decide all issues on facts and law, after appreciating the entire evidence.
• ✓ National Insurance Co. Ltd. vs. Naresh Kumar and Others, (2000) 10 SCC 158, Supreme Court of India: This case was referred to highlight that the High Court must appreciate all evidence when deciding an appeal under Section 173 of the Motor Vehicles Act.

On the standard of proof in claim cases:

• ✓ Sajeena Ikhbal and Others vs. Mini Babu George and Others, (2024) SCC OnLine SC 2883, Supreme Court of India: The Court held that in claim cases, the claimant is only required to prove the accident on a preponderance of probability, not beyond a reasonable doubt.
• ✓ Bimla Devi & Ors. V. Himachal Road Transport Corporation & Ors., (2009) 13 SCC 530, Supreme Court of India: This case was cited to support the view that strict proof of an accident may not be possible for claimants, and they need only establish their case on the touchstone of preponderance of probability.

On the burden of proof:

• ✓ Section 106 of the Evidence Act, 1872: The Court referred to this section in the context of the insurance company’s claim that the vehicle was wrongly implicated.

Summary of Authorities:

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• ✓ Sudarsan Puhan vs. Jayanta Ku. Mohanty and Others, (2018) 10 SCC 552*: The Supreme Court followed this authority to emphasize that appeals under Section 173 of the Motor Vehicles Act are in the nature of first appeals, requiring a comprehensive review.
• ✓ Uttar Pradesh State Road Transport Corporation vs. Mamta and Others, (2016) 4 SCC 172*: This authority was followed to highlight the High Court’s legal obligation to decide all issues on facts and law after appreciating the entire evidence.
• ✓ National Insurance Co. Ltd. vs. Naresh Kumar and Others, (2000) 10 SCC 158*: The Supreme Court followed this authority to emphasize that the High Court must appreciate all evidence when deciding an appeal under Section 173 of the Motor Vehicles Act.
• ✓ Sajeena Ikhbal and Others vs. Mini Babu George and Others, (2024) SCC OnLine SC 2883*: This authority was followed to reiterate that in claim cases, the claimant is only required to prove the accident on a preponderance of probability, not beyond a reasonable doubt.
• ✓ Bimla Devi & Ors. V. Himachal Road Transport Corporation & Ors., (2009) 13 SCC 530*: The Supreme Court followed this authority to support the view that strict proof of an accident may not be possible for claimants, and they need only establish their case on the touchstone of preponderance of probability.
• ✓ Section 106 of the Evidence Act, 1872: The Court referred to this provision regarding the burden of proof, noting that the insurance company, having set up a plea of collusion, had to discharge that burden, which they failed to do.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• ✓ The High Court’s summary reversal of the MACT award without proper consideration of evidence.
• ✓ The claimants’ establishment of the accident and the truck’s involvement based on the principle of preponderance of probability.
• ✓ The insurance company’s failure to prove collusion or wrongful implication of the vehicle.
• ✓ The lack of any complaint by the insurance company regarding the alleged wrongful involvement of the truck.

Sentiment Analysis of Reasons given by the Supreme Court:

Fact:Law Ratio:

Logical Reasoning:

The Supreme Court found that the High Court’s decision was a summary reversal of a well-reasoned award by the MACT. The High Court did not properly analyze the evidence presented and failed to consider key documents. The Supreme Court emphasized that the claimants had successfully established the involvement of the truck based on the principle of preponderance of probability. The insurance company, having alleged collusion, failed to provide any evidence to support their claim. The Court also noted that the insurance company did not raise any concerns with higher police authorities or the court regarding the alleged wrongful implication of the vehicle.

The Supreme Court stated, “It is well settled that in claim cases, in case the accident is disputed or the involvement of the vehicle concerned is put in issue, the claimant is only expected to prove the same on a preponderance of probability and not beyond reasonable doubt.” The Court also observed, “The standard of proof beyond reasonable doubt could not have been applied.” In addition, the Court noted, “We find that the judgment of the High Court is wholly untenable.”

There were no minority opinions in this judgment. The bench consisted of two judges, Justice B.R. Gavai and Justice K.V. Viswanathan, with the opinion authored by Justice K.V. Viswanathan.

The implications of this judgment are that High Courts must carefully review all evidence presented in appeals against MACT awards and that claimants are not required to prove their case beyond a reasonable doubt but only on the principle of preponderance of probability. The judgment also highlights that if an insurance company alleges collusion, it must provide evidence to support the claim.

Key Takeaways

• ✓ High Courts must conduct a thorough review of evidence in appeals against MACT awards.
• ✓ Claimants need only prove their case on the principle of preponderance of probability, not beyond reasonable doubt.
• ✓ Insurance companies alleging collusion must provide evidence to support their claims.
• ✓ The High Court cannot set aside a well reasoned award by the MACT with a summary order.

This judgment clarifies the standard of proof required in motor accident claim cases and emphasizes the importance of a thorough review of evidence by appellate courts. It also sets a precedent that insurance companies cannot simply allege collusion without providing supporting evidence.

Directions

The Supreme Court quashed and set aside the judgment of the High Court dated 24.08.2023 in MA No. 68 of 2022 and restored the award passed by the MACT, Maihar, District Satna, Madhya Pradesh dated 25.03.2021.

Specific Amendments Analysis

There is no discussion on specific amendments in the judgment.

Development of Law

The ratio decidendi of this case is that in motor accident claim cases, the claimant is only required to prove the accident and the involvement of the vehicle based on the principle of preponderance of probability, not beyond a reasonable doubt. The judgment also clarifies that an appeal under Section 173 of the Motor Vehicles Act requires a thorough review of facts and law, and that the High Court cannot set aside a well reasoned award by the MACT with a summary order. This case reinforces the principle that insurance companies, when alleging collusion, must provide evidence to support their claims.

Conclusion

In the case of Geeta Dubey & Ors vs. United India Insurance Co. Ltd. & Ors., the Supreme Court upheld the Motor Accident Claims Tribunal (MACT) award, emphasizing that claimants need only prove their case on the principle of preponderance of probability, not beyond a reasonable doubt. The Court criticized the High Court for summarily reversing the MACT award without proper consideration of evidence. The judgment reinforces the need for appellate courts to conduct a thorough review of evidence and highlights the burden on insurance companies to provide evidence when alleging collusion.