Supreme Court upholds reliance on police reports in motor accident claims: ICICI Lombard vs. Rajani Sahoo (2025) INSC 6 (2 January 2025)

Date of the Judgment: 2 January 2025
Citation: 2025 INSC 6
Judges: C.T. Ravikumar, J. and Rajesh Bindal, J.
Can police reports be the basis for deciding negligence in motor accident claims? The Supreme Court of India recently addressed this question. This case involves a claim for compensation after a fatal road accident. The court examined whether the Motor Accidents Claims Tribunal and the High Court were correct in relying on police records to determine negligence. The judgment was delivered by a two-judge bench of Justices C.T. Ravikumar and Rajesh Bindal.

Case Background

On April 27, 2009, Udayanath Sahoo was riding his motorcycle in Bahadajhola when a truck hit him from behind. This collision caused Udayanath’s motorcycle to crash into a tree. Udayanath Sahoo died from the injuries sustained in the accident. The pillion rider was also severely injured. The accident led to the registration of FIR No. 61/2009 at Sarankul Police Station. The legal heirs of Udayanath Sahoo filed a claim petition under Section 166 of the Motor Vehicles Act, 1988, seeking ₹10,50,000 in compensation. ICICI Lombard General Insurance Co. Ltd., the insurer of the truck, was the second respondent in the claim petition.

Timeline:

Course of Proceedings

The Motor Accidents Claims Tribunal, Nayagarh, awarded ₹6,77,164 with 7% annual interest from the date of filing the claim petition. The Tribunal relied on oral and documentary evidence, including police reports like the FIR and final report. ICICI Lombard General Insurance Co. Ltd. appealed to the High Court of Orissa, arguing that the accident was due to the deceased’s negligence. The High Court dismissed the appeal, upholding the Tribunal’s decision. The High Court also relied on the police’s final report, which found the truck driver guilty of rash and negligent driving. The insurer then appealed to the Supreme Court.

Legal Framework

The case is primarily based on Section 166 of the Motor Vehicles Act, 1988, which deals with compensation for motor vehicle accidents. This section allows the legal heirs of a deceased person to claim compensation for death or injury caused by a motor vehicle accident. The court also considered the principle of “preponderance of probabilities” as the standard of proof in motor accident claims, as opposed to “proof beyond reasonable doubt.”

Arguments

Appellant’s Arguments (ICICI Lombard):

• The appellant argued that the accident was solely due to the deceased’s rash and negligent driving.
• The insurer contended that the police chargesheet was fraudulent and prepared in collusion with the respondents.
• The appellant claimed that the Tribunal and the High Court erred in relying on the FIR and other police records.

Respondents’ Arguments (Rajani Sahoo & Ors.):

• The respondents argued that there was no illegality in relying on the FIR and final police report to determine negligence.
• They contended that the appellant failed to prove the alleged connivance between the respondents and the police.
• The respondents submitted that the evidence on record supported the finding of rash and negligent driving by the truck driver.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in the judgment. However, the core issue was:

• Whether the Tribunal and High Court were correct in relying on police records, including the FIR and final report, to determine negligence in a motor accident claim.

Treatment of the Issue by the Court

Authorities

The Supreme Court relied on the following authorities:

Cases:

• Mangla Ram v. Oriental Insurance Co. Ltd. and Ors., (2018) 5 SCC 656; 2018 INSC 311: The Court referred to this case to support the view that a charge sheet filed by the police prima facie points towards the driver’s complicity in driving the vehicle negligently. The court also noted that even if the accused were acquitted in the criminal case, it would not affect the assessment of liability in motor accident cases.
• Dulcina Fernandes v. Joaquim Xavier Cruz, (2013) 10 SCC 646: This case was cited to emphasize that negligence in motor accident claims should be decided based on the “preponderance of probability” and not “proof beyond reasonable doubt.”
• Mathew Alexander v. Mohammed Shafi & Anr., (2023) 13 SCC 510; 2023 INSC 621: The Court cited this case to reiterate that a holistic view of the evidence should be taken and that strict proof of an accident is not required. The claimants only need to establish their case on the touchstone of preponderance of probabilities.

Legal Provisions:

• Section 166 of the Motor Vehicles Act, 1988: This provision was considered as it deals with the procedure for claiming compensation in motor accident cases.

Judgment

How each authority was viewed by the Court:

• The Supreme Court in Mangla Ram v. Oriental Insurance Co. Ltd. and Ors., (2018) 5 SCC 656; 2018 INSC 311*, was followed to state that the charge sheet filed by the police is a prima facie evidence of the driver’s negligence.
• The Supreme Court in Dulcina Fernandes v. Joaquim Xavier Cruz, (2013) 10 SCC 646*, was followed to emphasize that the standard of proof in motor accident claims is “preponderance of probabilities” and not “proof beyond reasonable doubt.”
• The Supreme Court in Mathew Alexander v. Mohammed Shafi & Anr., (2023) 13 SCC 510; 2023 INSC 621*, was followed to reiterate that a holistic view of evidence is required in motor accident claims.

What weighed in the mind of the Court?

The Court was primarily influenced by the principle that in motor accident claims, the standard of proof is the “preponderance of probabilities” rather than “proof beyond reasonable doubt.” The Court emphasized that a holistic view of the evidence is necessary. The Court also noted that the police records, including the FIR and final report, are admissible and relevant in determining negligence. The concurrent findings of the Tribunal and the High Court were also a significant factor in the Court’s decision.

Logical Reasoning:

The Court considered the appellant’s argument that the chargesheet was fraudulent. However, the Court found no evidence to support this claim. The Court also considered the concurrent findings of the Tribunal and the High Court. The Court stated that it found no perversity in the judgments of the lower courts. The Court held that the police records are relevant and admissible for determining negligence in motor accident claims. The Court also emphasized that the standard of proof is based on the “preponderance of probabilities.”

The Court stated:

“The Tribunal had also taken note of the fact that based on the final report, the driver of the offending truck was tried and found guilty for rash and negligent driving.”

The Court further observed:

“A holistic view of the evidence has to be taken into consideration by the Tribunal and strict proof of an accident caused by a particular vehicle in a particular manner need not be established by the claimants.”

The Court also noted:

“If the police records are available before the Tribunal, taking note of the purpose of the Act it cannot be said that looking into such documents for the aforesaid purpose is impermissible or inadmissible.”

The Court found no reason to interfere with the concurrent findings of the Tribunal and the High Court. The Court dismissed the appeal.

Key Takeaways

• Police reports, including FIRs and final reports, are admissible as evidence in motor accident claims.
• The standard of proof in motor accident claims is the “preponderance of probabilities,” not “proof beyond reasonable doubt.”
• Courts can rely on police records to determine negligence in motor accident cases.
• Concurrent findings of lower courts are given due weight by the Supreme Court.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of this case is that police reports, including FIRs and final reports, are admissible as evidence in motor accident claims and the standard of proof is the “preponderance of probabilities.” This judgment reinforces the existing legal position regarding the admissibility of police records in motor accident cases and the standard of proof required.

Conclusion

The Supreme Court dismissed the appeal, upholding the decisions of the Motor Accidents Claims Tribunal and the High Court. The Court affirmed that police reports are valid evidence in motor accident claims and that the standard of proof is based on the “preponderance of probabilities.” This judgment clarifies the evidentiary value of police records in motor accident cases.

Category

Parent category: Motor Vehicle Act, 1988
Child category: Section 166, Motor Vehicle Act, 1988
Child category: Motor Accident Claims
Child category: Negligence
Child category: Evidence
Child category: Police Report

FAQ

Q: Can police reports be used as evidence in motor accident claims?
A: Yes, the Supreme Court has clarified that police reports, such as FIRs and final reports, are admissible as evidence in motor accident claims.

Q: What standard of proof is required in motor accident claims?
A: The standard of proof is based on the “preponderance of probabilities,” which means it is more likely than not that the accident occurred due to the negligence of the party in question. This is a lower standard than “proof beyond a reasonable doubt.”

Q: What should I do if I am involved in a motor accident?
A: If you are involved in a motor accident, you should file a police report. You should also seek legal advice to understand your rights and options for claiming compensation.