The Supreme Court upheld the High Court’s decision, emphasizing that a claim petition under motor accident law must be established on a preponderance of probability. However, this standard is not met when the foundational evidence, including the FIR and eyewitness testimony, is found to be unreliable, unsubstantiated, and creates valid suspicion regarding the occurrence of the accident itself.
Facts Of The Case:
On June 18, 2014, the deceased, husband of the first appellant, was allegedly involved in a hit-and-run road accident at Singasandra crossroad. The accident was claimed to be witnessed by PW2, a neighbour, who testified that the driver of the offending vehicle abandoned the victim’s body after promising to take him to a hospital. The wife of the deceased (PW1) was informed by PW2 and, after searching various hospitals, later discovered the body at a distant location. An FIR was registered at the Hebbogodi Police Station, a non-jurisdictional station, on June 19, 2014, and was transferred to the jurisdictional Electronic City Traffic Police Station after a delay of 117 days. The Motor Accidents Claims Tribunal initially awarded compensation to the claimants, rejecting the insurance company’s objections. However, the High Court reversed this award, finding the evidence unreliable. The Supreme Court, in its judgment, concurred with the High Court, highlighting the incredibility of the eyewitness account, the unexplained delay and jurisdictional defect in the FIR, and the subsequent acquittal of the driver in the related criminal case.
Procedural History:
The case originated with a claim petition filed by the appellants before the Motor Accidents Claims Tribunal. The Tribunal, rejecting the objections raised by the insurance company, awarded compensation to the claimants. The insurance company then filed an appeal before the High Court, which reversed the Tribunal’s award and dismissed the claim petition. Subsequently, the claimants appealed to the Supreme Court of India, which, after examining the evidence and procedural history, upheld the judgment of the High Court and dismissed the civil appeal.
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Court Observation:
The Supreme Court made crucial observations on the standard of proof in motor accident claims. It affirmed that while a case can be proved on the “preponderance of probabilities,” this standard is not met when the core evidence is unreliable. The Court found the eyewitness testimony (PW2) untrustworthy due to major contradictions and her status as a chance witness. It also held serious doubts regarding the FIR, noting its registration at a non-jurisdictional police station and the unexplained, inordinate delay in transferring it, which created a valid suspicion about the genuineness of the accident itself. The subsequent acquittal of the driver in the connected criminal case further fortified the conclusion that the claimants failed to discharge their burden of proof.
Final Decision & Judgement:
The Supreme Court dismissed the appeal and upheld the decision of the High Court. It found no merit in the claimants’ case, concluding that they had failed to prove the occurrence of the accident or the involvement of the alleged vehicle. The Court agreed with the High Court’s reasoning that the evidence, particularly the unreliable eyewitness testimony and the suspicious circumstances surrounding the FIR, was insufficient to establish the claim on a preponderance of probabilities. Consequently, the award of compensation granted by the Tribunal was set aside, and the claim petition stood rejected.
Case Details:
Case Title: Rajamma & Ors. versus M/s. Reliance General Insurance Co. Ltd. & Anr. Appeal Number: Civil Appeal No. 5172 of 2025 Date of Judgement: September 26, 2025 Judges/Justice Name: Justice K. Vinod Chandran and Justice N. V. Anjaria