Sunday, 2 March 2025

Supreme Court: Whether Motor Accident Claims Tribunal Can Look Into Police Records To Determine Question Of Negligence?

Thus, there can be no dispute with respect to the

position that the question regarding negligence which is

essential for passing an award in a motor vehicle

accident claim should be considered based on the

evidence available before the Tribunal. If the police

records are available before the Tribunal, taking note of

the purpose of the Act it cannot be said that looking into

such documents for the aforesaid purpose is

impermissible or inadmissible. {Para 9}

Non-Reportable

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

Civil Appeal No. of 2025 (@ SLP (C) No. 29302 of 2019)

ICICI Lombard General Insurance Co. Ltd. Vs Rajani Sahoo & Ors.

Author: C.T. RAVIKUMAR, J.

Citation:  2025 INSC 6.

1. Leave granted.

2. The insurer of the vehicle bearing Registration No.

OR-04-D-5675, held as the offending vehicle, filed the

captioned appeal against the judgment dated 07.02.2018

passed by the High Court of Orissa, at Cuttack in MACA

No.627 of 2016 dismissing the appeal filed against the

award dated 07.05.2016 passed by the Motor Accidents

Claims Tribunal, Nayagarh, in MAC No.57 of 2009. The

claim petition was filed by the respondents herein

seeking compensation for the death of one Udayanath

Sahoo who succumbed to the injuries sustained in a

motor vehicle accident involving the motorcycle, being

driven by him and the vehicle insured with the appellant.

The aforesaid offending vehicle dashed against the rear

side of the motorcycle ridden by the deceased

Udayanath Sahoo when he was going to Bahadajhola at

about 01.10 pm on 27.04.2019. Consequent to the hit, the

motorcycle dashed against a tree standing by the road

and Udayanath Sahoo succumbed to the injuries

sustained and the pillion got severely injured. In

connection with the accident, FIR No.61/2009 was

registered at Police Station Sarankul. The legal heirs of

deceased Udayanath Sahoo, the respondents herein

filed a claim petition under Section 166 of the Motor

Vehicle Act, 1988 (for short, the MV Act) claiming

compensation of ₹ 10,50,000/-. The appellant was the

second respondent therein. On appreciating the

evidence consisting both oral and documentary, the

Tribunal passed an award for ₹ 6,77,164/- along with the

interest at the rate of 7% per annum from the date of

filing of the claim petition till the actual payment.

3. Feeling aggrieved by the award passed by the

Tribunal contending that the accident had occurred

solely on account of the rash and negligent driving on the

part of the deceased and not at all due to the rash and


negligent driving of the driver of the truck, which was

insured with the appellant and further that the Tribunal

had erred in relying on the FIR and the other records, the

appeal bearing No. MACA No.627/2016 was filed by the

appellant herein, which was dismissed by the High Court

as per the impugned judgment. Hence, this appeal.

4. Heard the learned counsel for the appellant as also

the learned counsel appearing for the respondents.

5. For understanding the case of the appellant, it is

only appropriate to refer to the operative portion of the

impugned judgment which reads thus:-

“On a perusal of the impugned award it is

seen that the learned Tribunal has taken into

consideration the evidence available on

record, both oral and documentary,

including the police papers such as, F.I.R.

(Exts. 1 and 2), Final Form (Ext. 3) and the

evidence of eye-witness (P.W. 2), in coming

to hold that the driver of the offending truck

no. OR-04-D/5675 was rash and negligent in

causing the accident, which resulted in the

death of Udayanath Sahoo, the rider of the

motorcycle.

There is no dispute that in the Final Form

submitted by the police after investigation,

the accused driver of the offending Truck has

been found to be guilty of rash and negligent

driving, which resulted in the death of

Udayanath Sahoo, the rider of the

motorcycle no. OR-205/2229. Therefore, the

impugned findings of the learned Tribunal

cannot be faulted.”

6. The core contention of the appellant is that the

Tribunal as also the High Court relied on the fraudulent

chargesheet prepared by the respondents in connivance

with the police. In short, the contention of the appellant

is that the High Court erred in relying on the chargesheet

to arrive at the conclusion that the accident in question in

which Udayanath Sahoo lost his life had occurred due to

the rash and negligent driving of the truck insured with

the appellant. Though respondent Nos.1 and 2 did not

file any counter affidavit, the learned counsel appearing

for them would submit that there is absolutely no

illegality in relying on such documents consisting of FIR

and the final report prepared in relation to the accident

in question by the police, for the purpose of considering

the question of negligence in a motor vehicle accident

case. That apart, it is contended that the appellant

despite attributing connivance of the respondents with

the police, the appellant failed to prove the same. In

short, it is submitted that the appeal is devoid of merit

and the same is liable to be dismissed.


7. As regards the reliability of charge sheet and other

documents collected by the police during the

investigation in motor accident cases, this Court in the

case of Mangla Ram v. Oriental Insurance Co. Ltd. and

Ors.1

, held in paragraph No.27, thus : -

“27. Another reason which weighed with the

High Court to interfere in the first appeal

filed by Respondents 2 & 3, was absence of

finding by the Tribunal about the factum of

negligence of the driver of the subject jeep.

Factually, this view is untenable. Our

understanding of the analysis done by the

Tribunal is to hold that Jeep No. RST 4701

was driven rashly and negligently by

Respondent 2 when it collided with the

motorcycle of the appellant leading to the

accident. This can be discerned from the

evidence of witnesses and the contents of the

charge-sheet filed by the police, naming

Respondent 2. This Court in a recent

decision in Dulcina Fernandes [Dulcina

Fernandes v. Joaquim Xavier Cruz, (2013) 10

SCC 646, noted that the key of negligence on

the part of the driver of the offending vehicle

as set up by the claimants was required to be

decided by the Tribunal on the touchstone of

preponderance of probability and certainly

not by standard of proof beyond reasonable

 1 (2018) 5 SCC 656; 2018 INSC 311

SLP (C) No. 29302 of 2019 Page 6 of 8

doubt. Suffice it to observe that the

exposition in the judgments already

adverted to by us, filing of charge-sheet

against Respondent 2 prima facie points

towards his complicity in driving the vehicle

negligently and rashly. Further, even when

the accused were to be acquitted in the

criminal case, this Court opined that the

same may be of no effect on the assessment

of the liability required in respect of motor

accident cases by the Tribunal”.

 (Emphasis Supplied)

8. It is true that the Tribunal had looked into the oral

and documentary evidence including the FIR, final

report and such other documents prepared by the police

in connection with the accident in question. The Tribunal

had also taken note of the fact that based on the final

report, the driver of the offending truck was tried and

found guilty for rash and negligent driving. The High

Court took note of such aspects and found no illegality in

the procedure adopted by the Tribunal and

consequently dismissed the appeal. In the contextual

situation it is relevant to refer to a decision of this Court

in Mathew Alexander v. Mohammed Shafi & Anr. (2023) 13 SCC 510; 2023 INSC 621, this

Court held thus:-

“12….A holistic view of the evidence has to be

taken into consideration by the Tribunal and

strict proof of an accident caused by a

particular vehicle in a particular manner need

not be established by the claimants. The

claimants have to establish their case on the

touchstone of preponderance of

probabilities. The standard of proof beyond

reasonable doubt cannot be applied while

considering the petition seeking

compensation on account of death or injury in

a road traffic accident. To the same effect is

the observation made by this Court in Dulcina

Fernandes vs. Joaquim Xavier Cruz, (2013) 10

SCC 646 which has referred to the aforesaid

judgment in Bimla Devi.”

9. Thus, there can be no dispute with respect to the

position that the question regarding negligence which is

essential for passing an award in a motor vehicle

accident claim should be considered based on the

evidence available before the Tribunal. If the police

records are available before the Tribunal, taking note of

the purpose of the Act it cannot be said that looking into

such documents for the aforesaid purpose is

impermissible or inadmissible.

10. It is also a fact that the appellant had attributed that

the respondent claimants connived with police and

fraudulently prepared the chargesheet. The contention

is that the vehicle insured with the appellant was not

involved in the accident and the accident had occurred

solely due to the rash and negligence on the part of the

deceased. But the evidence on record would reveal that

pursuant to the filing of the final report, cognizance was

taken for rash and negligent driving which resulted in

the death of Udayanath Sahoo.

11. In view of the aforementioned circumstances and

taking note of the concurrent findings of the Tribunal and

the High Court, we do not find any perversity in the

impugned judgment warranting interference by this

Court. Resultantly, the appeal must fail and consequently

it is dismissed.

……………………, J.

 (C.T. Ravikumar)

……………………, J.

 (Rajesh Bindal)

New Delhi;

January 02, 2025.

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