Supreme Court Reinstates Accident Claim: FIR and Chargesheet Sufficient to Prove Negligence Without Eyewitness

The Supreme Court of India recently delivered a significant judgment in the case of Meera Bai & Ors. vs ICICI Lombard General Insurance Company Ltd. & Anr., setting aside the High Court’s order that had dismissed a motor accident claim petition for lack of eyewitness testimony. The judgment, delivered by Justices Sudhanshu Dhulia and K. Vinod Chandran on April 30, 2025, restored the compensation awarded by the Motor Accident Claims Tribunal (MACT) to the family of a pillion rider who died in a motorcycle accident.

The case involved a fatal accident that occurred on January 29, 2015, where the deceased was traveling as a pillion rider on a motorcycle owned and driven by the second respondent. While the FIR was lodged and chargesheet filed against the motorcycle owner for rash and negligent driving, the High Court had dismissed the claim petition solely because no eyewitness was examined to prove negligence.

The Supreme Court strongly disagreed with this approach, observing that “As far as examining the eyewitness, such a witness will not be available in all cases. The FIR having been lodged and the charge sheet filed against the owner driver of the offending vehicle, we are of the opinion that there could be no finding that negligence was not established.” This observation underscores the Court’s recognition of practical realities in accident cases where eyewitnesses may not always be available.

Read also: https://judgmentlibrary.com/supreme-court-modifies-compensation-in-fatal-bike-accident-case-expands-consortium-rights/

The judgment noted that while the owner-driver had filed a written statement denying negligence, he failed to testify before the Tribunal to substantiate his claims. The Court emphasized that “the owner driver filed a written statement before the Tribunal denying the rash and negligent driving on his part, however he did not mount the box to depose that it was not due to his fault that the accident occurred.” This failure to testify was seen as significant in evaluating the merits of the case.

In its decision, the Supreme Court restored the Tribunal’s award, directing the insurance company to pay the compensation amount with 7% interest from the date of filing the claim petition. The Court specifically refrained from commenting on the quantum of compensation as it was not challenged by the claimants. The judgment states: “We do not speak on the quantum, since there is no appeal filed by the claimants against the quantum as determined by the Tribunal.”

This ruling reinforces the principle that formal police documents like FIR and chargesheet carry evidentiary value in establishing negligence in motor accident cases, especially when the opposing party fails to provide contrary evidence. The judgment serves as an important precedent for similar cases where direct eyewitness testimony might be unavailable, ensuring that technicalities don’t deprive accident victims of rightful compensation.

Petitioner Name: Meera Bai & Ors..
Respondent Name: ICICI Lombard General Insurance Company Ltd. & Anr..
Judgment By: Justice Sudhanshu Dhulia, Justice K. Vinod Chandran.
Place Of Incident: Not specified in judgment.
Judgment Date: 30-04-2025.
Result: allowed.

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