Supreme Court Reversal on Vehicle Involvement in Fatal Accident: A Detailed Analysis of MACT's Decision.


18 December 2024 Civil Appeals >> Civil & Consumer Law   |   FIR >> Criminal Law   |   Investigation >> Criminal Law   |   Motor Accident >> Family Law  

This case of Geeta Dubey & Others v/s United India Insurance Co. Ltd. & Others concerns the appeal filed by the claimants challenging the decision of the High Court of Madhya Pradesh, which set aside the award of compensation granted by the First Additional Motor Accident Claims Tribunal (MACT) in favor of the claimants. The MACT had awarded a sum of Rs. 50,41,289 to the wife and son of the deceased, Chakradhar Dubey, who died as a result of a road accident.

The claimants contended that the deceased was involved in a car accident on June 18, 2018, where a truck (bearing registration MP-19-HA-1197) hit their car from behind, causing serious injuries to the deceased, who later died from his injuries. The First Information Report (FIR) was filed, mentioning the truck involved as "unknown" at the time of the accident. The investigation later confirmed the involvement of the truck, with eyewitnesses coming forward to support the claim.

 
 

Despite this, the insurance company disputed the claim, mainly arguing that the truck's involvement was not conclusively proven and claiming contributory negligence on the part of the car's driver. The MACT, after considering the evidence, concluded that the truck was indeed involved in the accident and awarded compensation to the claimants.

However, on appeal, the High Court reversed the MACT's decision, citing deficiencies in the evidence presented by the claimants, such as the delay in pursuing the case and the lack of evidence like CCTV footage or the truck's number being provided promptly. The High Court also questioned why the truck's number was not communicated sooner by witnesses.

The Supreme Court, hearing the case, found that the High Court had not sufficiently considered the available evidence and had dismissed the claim too abruptly. It held that in cases like this, claimants are only required to prove the involvement of the vehicle on a preponderance of probability, not beyond reasonable doubt. It further noted that the evidence, including witness testimony and police investigation, was sufficient to establish the truck's involvement in the accident.

The Court concluded that the MACT's award was valid and that the High Court erred in setting it aside. Consequently, the Supreme Court restored the MACT's findings and rejected the insurance company's claim of collusion, given their failure to substantiate their case. The issue of the appropriate multiplier to be applied in determining compensation was not argued in detail, but the Court noted that the MACT's application of a multiplier of 11 was consistent with the evidence presented.

The case emphasizes the importance of careful consideration of all evidence and highlights that in motor accident claims, claimants are only required to prove their case on a preponderance of probability, not beyond reasonable doubt.


Section 133, Motor Vehicles Act - 1988  

Section 173, Motor Vehicles Act - 1988  

Motor Vehicles Act, 1988