The Supreme Court held that the High Court erred in disregarding the testimony of the eyewitness (PW-1) and documentary evidence (FIR, charge sheet) while relying on an unproven police statement (Ex-D1). It reinstated the MACT’s compensation award, ruling that the insurer failed to disprove negligence by the offending vehicle’s driver under Section 166 of the MV Act. The Court emphasized that non-examination of additional witnesses or delayed reporting was not fatal to the claim. Compensation of ₹12.43 lakhs was upheld, with 85% apportioned to the deceased’s wife.
Facts Of The Case:
On September 24, 2021, Nathuram Ahirwar was riding a motorcycle with his wife (PW-1) as a pillion rider when their vehicle was allegedly hit from behind by a mini-truck (APE pickup) bearing registration MP 04 GB 5604. The collision caused both to fall, resulting in severe injuries to Nathuram, who later succumbed on October 1, 2021, during treatment. The claimants (Nathuram’s wife and children) filed a petition under Section 166 of the Motor Vehicles Act, seeking ₹1.88 crore in compensation, alleging rash and negligent driving by the mini-truck driver. The insurer contested the claim, arguing that the accident occurred due to the deceased losing balance, not due to any collision, and that the claimants had conspired with the truck driver, who lacked a valid license.The Motor Accidents Claims Tribunal (MACT) awarded ₹12.43 lakhs, accepting the claimants’ evidence, including the FIR, medical reports, and eyewitness testimony. However, the High Court overturned this decision, citing inconsistencies in PW-2’s (claimant’s son) police statement and the non-examination of the son-in-law, who allegedly noted the truck’s number. The Supreme Court reversed the High Court’s ruling, emphasizing that PW-1’s eyewitness account and corroborative documents (charge sheet, FIR) established negligence, while the insurer failed to prove Ex-D1’s authenticity. The compensation was restored, apportioning 85% to the widow.
Procedural History:
The case originated with the filing of a claim petition under Section 166 of the Motor Vehicles Act, 1988, before the Motor Accidents Claims Tribunal (MACT), Deori, Sagar (M.P.), seeking compensation of ₹1.88 crore for the death of Nathuram Ahirwar in a vehicular accident. The MACT, after evaluating evidence including eyewitness testimony (PW-1, the deceased’s wife), medical records, and the FIR, ruled in favor of the claimants and awarded ₹12.43 lakhs with 6% interest.Dissatisfied, the insurer (Cholamandalam MS General Insurance Co. Ltd.) appealed to the High Court of Madhya Pradesh, which set aside the MACT’s award, primarily doubting the claimants’ version due to alleged inconsistencies in PW-2’s police statement and the non-examination of the son-in-law. The claimants then approached the Supreme Court via Special Leave Petition (Civil) No. 25092 of 2024.The Supreme Court, in its July 14, 2025 judgment, reversed the High Court’s decision, restoring the MACT’s award. It held that the High Court erred in discarding credible evidence (PW-1’s testimony, FIR, and charge sheet) while relying on an unproven police statement (Ex-D1). The SC emphasized that the insurer failed to discharge its burden of disproving negligence and affirmed the compensation, modifying the apportionment to allocate 85% to the widow and 15% to the children. No costs were awarded, and pending applications were disposed of.
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Court Observation:
The Supreme Court made several critical observations while overturning the High Court’s judgment. It emphasized that the eyewitness testimony of PW-1 (the deceased’s wife), who was present during the accident, carried substantial weight and should not have been disregarded. The Court noted that the FIR, medical records, and charge sheet conclusively established the involvement of the offending vehicle and the negligence of its driver.The Court criticized the High Court for relying on Ex-D1 (PW-2’s alleged police statement) without proper authentication, as the investigating officer was not examined to verify its validity. It held that mere inconsistencies in witness statements or delayed reporting do not invalidate a claim, especially when the claimants were preoccupied with medical emergencies.Additionally, the Court observed that the insurer failed to discharge its burden of proof under the Motor Vehicles Act to disprove negligence or collusion. It also clarified that non-examination of additional witnesses (like the son-in-law) was not fatal to the claim, as the available evidence was sufficient. The compensation awarded by the MACT was deemed just, with adjustments made only in the apportionment ratio.
Final Decision & Judgement:
The Supreme Court allowed the appeal in part, setting aside the High Court’s judgment and restoring the compensation award of ₹12,43,324/- granted by the Motor Accidents Claims Tribunal (MACT). The Court held that the claimants had successfully proved negligence on the part of the offending vehicle’s driver under Section 166 of the Motor Vehicles Act, based on the eyewitness testimony of PW-1 (the deceased’s wife), corroborated by documentary evidence including the FIR, medical records, and charge sheet. The Court rejected the insurer’s defence, noting its failure to disprove the claimants’ case or authenticate Ex-D1 (the disputed police statement).While maintaining the compensation amount, the Supreme Court modified the apportionment, directing 85% to be paid to the deceased’s widow (Appellant No. 1) and the remaining 15% equally distributed among the other claimants (Appellants 2-4). The Court clarified that non-examination of additional witnesses did not weaken the claimants’ case, as the evidence on record was sufficient. No costs were awarded, and any pending applications were disposed of. The judgment, delivered by Justices J.K. Maheshwari and Aravind Kumar on July 14, 2025, reinforced the principle that credible eyewitness testimony and official investigative reports must prevail over unsubstantiated technical objections in motor accident claims.
Case Details:
Case Title:Suhagrani & Others vs. Manager, Cholamandalam MS General Insurance Co. Ltd. Citation:2025 INSC 837 Nature of Appeal:Special Leave Petition (Civil) No. 25092 of 2024) Date of Judgment:July 14, 2025 Bench: Justice J.K. Maheshwari & Justice Aravind Kumar
Download The Judgement Here