Minor Discrepancies Cannot Defeat Motor Accident Claim Decided on Probability, Supreme Court Holds

A Division Bench of the Supreme Court set aside concurrent findings of the MACT and Calcutta High Court, awarding Rs. 14,90,000 to a permanently disabled labourer's legal heirs.

The Supreme Court has set aside concurrent orders of the Motor Accident Claims Tribunal and the Calcutta High Court that had denied compensation to a brick-field labourer who suffered traumatic paraplegia and 100% permanent disability after being struck by a lorry in May 2004. A Division Bench of Justice Vikram Nath and Justice Sandeep Mehta held that courts below had applied a standard of proof beyond reasonable doubt to a welfare claim that required only a preponderance of probability. The Bench found that each discrepancy in the record — a variant vehicle registration number in oral testimony, a phrase in an MRI report, delay in lodging the FIR, and gaps in hospital receipts — had been treated as individually fatal, when none went to the root of the occurrence. The Court determined compensation at Rs. 14,90,000 and directed the insurer to deposit the amount with interest at 6% within three months.

How the Dispute Reached the Supreme Court

On 21 May 2004, at around 5:00 p.m., Raj Kumar Das alighted from a rickshaw near Mondalpara Bus Stop. He deposed that while paying the rickshaw fare, a lorry bearing registration No. WB-41-3999 struck him, causing him to lose consciousness. He was subsequently diagnosed with traumatic paraplegia and rendered permanently disabled.

Das filed a claim petition — MACC No. 49/2005, later renumbered MACC 163/2007 — before the Motor Accident Claims Tribunal under Section 163A of the Motor Vehicles Act, 1988, seeking Rs. 3,50,000 in compensation. The Tribunal dismissed the petition on 11 September 2007, holding that he had failed to prove the injuries were caused by the alleged accident.

Das appealed to the Calcutta High Court in FMA No. 1056/2009. The High Court dismissed the appeal on 27 September 2022, finding that discrepancies in the record were glaring and that the factum of the accident had not been proved. Das died during the pendency of proceedings and was represented before the Supreme Court by his legal representatives. The Supreme Court granted leave and took up the civil appeal arising out of SLP (C) No. 3585 of 2023.

The Standard of Proof Under Section 163A

The Court identified the central question as whether the material on record reasonably established that the injuries arose out of the accident — not whether every detail stood proved with precision.

It reiterated that proceedings under the Motor Vehicles Act are summary in nature. A claim petition is to be decided on the touchstone of preponderance of probability, not proof beyond reasonable doubt. Under Section 163A specifically, the enquiry is narrower still: negligence need not be proved, and it is sufficient that the injury is reasonably connected with the motor vehicle in question.

The Court drew on its earlier decision in Mathew Alexander v. Mohammed Shafi & Anr., (2023) 13 SCC 510, which had itself referred to Dulcina Fernandes v. Joaquim Xavier Cruz, (2013) 10 SCC 646, and Bimla Devi, for the proposition that a holistic view of evidence must be taken and strict proof of an accident caused by a particular vehicle in a particular manner need not be established.

From this, the Court drew a working principle: discrepancies that do not go to the root of the occurrence cannot defeat a claim. Courts must differentiate between contradictions that render the accident improbable and those that merely reflect imperfections in documentation.

Examining Each Discrepancy Relied Upon Below

The MRI report entry. Both the Tribunal and the High Court had relied on an entry in the MRI report reading “fall from lorry” to deny the factum of the accident. The Court held that medical history recorded during emergency treatment is ordinarily based on information supplied by attendants and its only function is to facilitate diagnosis. Such a narration cannot be treated as a precise reconstruction of the mechanics of the accident. The FIR, chargesheet, and Das's own testimony — including his specific denial in cross-examination of having fallen from the lorry — constituted the cumulative evidentiary record, which the isolated wording in the history column could not displace.

Delay in lodging the FIR. The FIR was registered on 8 August 2004, while Das remained under continuous treatment and was frequently hospitalised until 17 September 2004. The Court observed that in cases involving grievous injuries, priority is naturally given to securing medical treatment rather than attending to legal formalities. The Court also pointed out that the precedent the High Court itself had relied upon — Ravi v. Badrinarayan, (2011) 4 SCC 693 — noted that delay in filing an FIR cannot be a ground to doubt the claimant's case. The investigation had culminated in a chargesheet attributing negligent driving to the lorry, which further undermined the inference drawn by the courts below.

Variation in vehicle registration number. Das stated in his oral evidence that the vehicle bore registration No. WB-41-2999, while the FIR, chargesheet, and claim petition uniformly recorded it as WB-41-3999. The Court held that an isolated error in oral testimony — particularly where the claimant was asked to recall events after suffering serious injuries — cannot outweigh contemporaneous documentary consistency. The High Court's observation that the statements did not corroborate each other was characterised as unsustainable.

Hospital receipts. The High Court had noted that certain hospital receipts did not fully correspond with Das's narration of treatment. The Court held that medical documents primarily establish the fact and extent of injury and the course of treatment; they are not expected to reproduce the claimant's testimony in precise detail. So long as the records consistently indicated hospitalisation and treatment for traumatic paraplegia, minor inconsistencies in dates or individual receipts did not render the claim unreliable.

Absence of independent witnesses. The Court relied on Sunita and others v. Rajasthan State Road Transport Corporation and others, (2020) 13 SCC 486, for the proposition that the approach in accident claim cases is not to find fault with the non-examination of the best eyewitness, but to analyse the evidence on record to ascertain whether it is sufficient to answer the matters in issue on the touchstone of preponderance of probability. Since Das had himself deposed to the occurrence and his testimony had not been shaken in cross-examination, the claim could not be rejected solely for want of additional evidence.

Cumulative Assessment and the Welfare Purpose of the Statute

The Court held that each discrepancy had been treated as fatal by the courts below, when a claim under the Act must be assessed on cumulative probabilities. When considered together with the police investigation, medical evidence, and consistent narrative across documents, the irregularities were not of material significance so as to render the occurrence improbable. In treating them as determinative, the courts below had applied the higher threshold of proof beyond reasonable doubt rather than the standard of probability applicable under this welfare legislation.

The Court also addressed the claimant's circumstances directly. Das had been a labourer in a brick field and the sole earning member of his family. Upon suffering permanent paralysis, he lost his entire earning capacity. Denying his claim despite the accident being established on a balance of probabilities would, the Court said, undermine the protective purpose the statute provides for.

The Court added that adjudication under the Act must not adopt a hyper-technical approach. Victims of accidents are seldom in a position to procure precise documents or give a coherent narration of events while undergoing treatment. “The absence of perfect proof cannot be a ground to deny compensation under a welfare statute.”

Determining Compensation Under Article 142

The claim had been filed under Section 163A, which at the relevant time provided a no-fault liability framework with compensation calculated under the structured formula in the Second Schedule of the Act. The Court acknowledged this but noted that the amounts contemplated in the Second Schedule would not adequately recompense a victim who suffered 100% permanent disability, given the passage of time and the subsequent evolution of the law on just compensation.

The Court referred to U.P. State Road Transport Corporation v. Trilok Chandra, (1996) 4 SCC 362, where a three-judge bench had observed that the calculation of compensation under the Second Schedule suffers from several defects and that the Table can only be used as a guide. It also referred to National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, for the principle that compensation must remain fair, realistic, and commensurate with actual loss.

The Court further noted that Das may not have invoked the provision best suited to the nature of his claim, but that lack of legal awareness could not operate to deny just compensation once the foundational facts stood established. Families of accident victims often approach the legal process without adequate legal assistance or awareness of technical distinctions between different provisions of the Act.

Accordingly, in exercise of jurisdiction under Article 142 of the Constitution, the Court determined compensation by drawing guidance from the principles evolved in claims under Section 166 of the Act. It made clear that this course was adopted keeping in view the peculiar facts of the case and shall not be treated as a precedent.

The accident was of the year 2004 and the claim had been pending for over two decades. The Court declined to remand the matter, finding that the material necessary for computation — age, income, and extent of disability — was already on record.

Compensation Calculation

Applying the principles from Sarla Verma & Ors. v. DTC & Anr., (2009) 6 SCC 121, and Pranay Sethi, the Court computed compensation as follows. Das was 37 years old at the time of the accident with a monthly income of Rs. 2,500. Adding future prospects at 40% brought the monthly figure to Rs. 3,500, giving an annual income of Rs. 42,000. Applying a multiplier of 15 and accounting for 100% disability, the loss of earning capacity was assessed at Rs. 6,30,000. The Court added Rs. 2,00,000 for mental agony, pain and suffering; Rs. 1,00,000 for loss of amenities; Rs. 3,60,000 for attendant charges; and Rs. 2,00,000 for transportation and medical expenses including future expenses. The total compensation was assessed at Rs. 14,90,000.

The appellants had placed on record a computation claiming Rs. 36,90,000. The Court did not adopt that figure and determined compensation independently in accordance with settled principles.

Order

The Supreme Court allowed the appeal and set aside the judgments of the MACT and the Calcutta High Court. National Insurance Co. Ltd. was directed to deposit Rs. 14,90,000 together with interest at 6% per annum from the date of filing the claim, within three months from the date of the order, before the MACT. Upon such deposit, the MACT was directed to forthwith release the amount to the legal representatives of Raj Kumar Das in accordance with law. Pending applications, if any, were disposed of.