Thursday, 9 October 2025

Supreme Court: Fake License By Driver Doesn't Absolve Insurer in motor accident claim petition Unless Vehicle Owner Knowingly Allowed Breach

As has been noticed in Geeta Devi (supra) there is no

pleading or substantiation of due diligence having not been

employed at the time of entrustment. R1W1 was the

Advertising In-charge of the appellant who produced the

licence before the Court as Exhibit R1W1/1. The certificate

issued by the RTO Gurdaspur was also marked as R1 which

we referred to from the additional documents. In cross

examination, there was only a bland suggestion made to the

witness that the Directors of R2 knew that R1 possessed only

a fake driving licence. There were no questions put to the

witness, who was examined on behalf of the owner, as to the

actual entrustment of the vehicle or whether R1 was

employed regularly or temporarily and when such

employment commenced, which are crucial insofar as

proving or disproving due diligence by the owner at the time

of engagement of the driver and the entrustment of the

vehicle. As has been rightly held by the precedents above

noticed, the owner of a vehicle employing a driver can only

look at the licence produced by the person seeking

employment and is not expected to verify from the licence

issuing authority whether the licence is fake or not. {Para 16}

17. The insurance company from the totality of the

circumstances has to bring out the absence of due diligence

in the employment of the driver or the entrustment of the

vehicle, to prove breach by the insured, which is totally

absent in the present case.

Reportable

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

Civil Appeal Nos.12442-12446 of 2024

Hind Samachar Ltd. (Delhi Unit). Vs  National Insurance Company Ltd. & Ors.

Author: K. VINOD CHANDRAN, J.

Citation: 2025 INSC 1204

1. The appellant is the owner of a truck, involved in an

accident in which nine persons lost their lives and two

sustained injuries; passengers in another vehicle, a Matador

van. The appeal is against the “pay and recovery” directions

granted to the insurance company which had insured the

truck. The breach complained of and found in favour of the

insurance company by the High Court was of the driver of the

offending vehicle having produced a fake driving licence.

The High Court was considering also the quantum appeals in

which some modifications were made, with which we are not

concerned. The insurance companies; both of the truck and

the Matador van; found to be compositely negligent,

apportioned at the rate of 75:25, had paid the compensation

to the claimants.

2. Mr.Gopal Shankaranarayan, learned Senior Counsel

appearing for the appellant contended that the Tribunal

despite having noticed the two driving licences produced

directed the insurance company to indemnify the owner of

the vehicle, which is perfectly in order looking at the binding

precedents. The High Court has gone on surmises and

conjectures in presuming that the owner of the vehicle, the

appellant herein, had colluded with its driver to obtain a fake

licence based on a register produced from the office of the

District Transport Officer, Gurdaspur, which by reason of

many interpolations made therein could not have been relied

upon. The testimony of the witness, a Clerk from the office of

DTO was against the certificate issued by the very same

office, which had also indicated that the driving licence

issued was later renewed.

3. The High Court had also observed that the driving

licence seized from the driver of the vehicle, at the accident

spot, was a different one and also proved to have been not

issued from the office of RTO, Alwar. The same was produced

by the Clerk of the record room in Tis Hazari Court, Delhi with

the specific statement in the deposition that it was seized by

them. The Tribunal had specifically noticed that the Clerk of

the record room or the Court staff could not have made any

such seizure. The learned Senior Counsel relied upon the

decisions of this Court in United India Insurance Company

v. Lehru and Ors.(2003) 3 SCC 338

, National Insurance Co. Ltd. v. Swaran Singh2 and PEPSU RTC v. National Insurance Co. Ltd.3 and

IFFCO Tokio General Insurance Co. Ltd. v. Geeta Devi4.

4. Dr. Manish Singhvi, learned Senior Counsel appearing

for the respondent-insurance company pointed out that both

the licences produced; by the police and that produced by

the owner, were found to be fake. The registered owner of

the truck, hence, can be safely found to have been negligent

while entrusting the vehicle to the driver. It is vehemently

contended that unlike the usual practice of the driver

producing the driving licence, here, the owner’s

representative had produced it before the Tribunal which

clearly indicates a collusion. The driver was not examined

before the Tribunal. The Clerks of both DTO Gurdaspur and

RTO Alwar had deposed that the licences said to have been

issued from their office respectively R1W1/1 and A2 were not

actually issued from the said offices. There is absolutely no

reason to interfere with the finding of the High Court, and the

2

(2004) 3 SCC 297

3

(2013) 10 SCC 217

4 2023 SCC OnLine SC 1398


insurance company is definitely entitled to recover the

amounts from the appellant-owner of the truck.

5. Suffice it to notice that the accident occurred on

26.01.1993 at 02:00 am at an intersection when the two

vehicles, a truck and the Matador van carrying ten

passengers collided. The claim petitions filed before the

Tribunal were all of the passengers in the Matador van,

including the driver. Nine petitions were filed for

compensation for death occasioned and two, for the injuries

sustained as also one petition for the damage caused to the

Matador van. Before the Tribunal, the first respondent-the

driver of the truck, the second respondent-its owner and the

third respondent-the insurer, were impleaded, as originally

filed. On objection being raised by the insurer, alleging

negligence on the Matador van driver also, the owner and the

insurer of the van were impleaded subsequently as the 4th

and 5th respondents.

6. The Tribunal looked at the FIR, analysed the deposition

of PW-3, an injured in the accident who was travelling in the

Matador, and examined the site plan to find composite

negligence on the driver of both vehicles at the rate of 75:25.

The compensation was determined and appeals were filed by

both the insurance company and the owners of the vehicle,

challenging respectively the liability and the quantum. As we

noticed, we are only concerned with the “pay and recover”

directions issued by the High Court in favour of the insurer

and against the insured owner of the truck.

7. Lehru (supra) was a case in which though an allegation

of the driving licence produced being fake was raised, the

same was not proved before the Tribunal. The trite law was

noticed that even if the licence is fake, the insurance

company is liable to pay compensation, if they fail to prove

that the insured had deliberately committed breach in

entrusting the vehicle to a driver who had a fake licence. New

India Assurance Co. v. Kamla5 wherein despite finding

breach, the insurer was directed to pay compensation to the

third parties, but, enabled recovery from the insured was

noticed. It was categorically held that whether the insured

would be protected by such an order was left open to be

5

(2001) 4 SCC 342


considered on the facts of each case. It was held in Lehru and

Ors. (supra) that: -

“18……we are thus in agreement with what is laid

down in the aforementioned cases viz. that in order

to avoid liability it is not sufficient to show that the

person driving at the time of accident was not duly

licensed. The Insurance Company must establish

that the breach was on the part of the insured.”

8. In Swaran Singh (supra), a three Judge Bench of this

Court, considered the purported conflict in Kamla (supra)

and Lehru and Ors. (supra) to hold as under: -

“99. So far as the purported conflict in the

judgments of Kamla (2001) 4 SCC 342 and Lehru

(2003) 3 SCC 338 is concerned, we may wish to

point out that the defence to the effect that the

licence held by the person driving the vehicle was

a fake one, would be available to the insurance

companies, but whether despite the same, the plea

of default on the part of the owner has been

established or not would be a question which will

have to be determined in each case.”

9. In PEPSU RTC (supra) it was held so on the facts arising

in the said case, as under: -


“11. On facts, in the instant case, the appellant

employer had employed the third respondent

Nirmal Singh as driver in 1994. In the process of

employment, he had been put to a driving test and

he had been imparted training also. The accident

took place only after six years of his service in PRTC

as driver. In such circumstances, it cannot be said

that the insured is at fault in having employed a

person whose licence has been proved to be fake

by the Insurance Company before the Tribunal. As

we have already noted above, on scanning the

evidence of the licensing authority before the

Tribunal, it cannot also be absolutely held that the

licence to the driver had not been issued by the said

authority and that the licence was fake. Though the

appellant had also taken a contention that the

compensation is on the higher side, no serious

attempt has been made and according to us

justifiably, to canvas that position.”

10. In Geeta Devi (supra) this Court deprecated the

practice of the insurance companies blithely claiming that the

deceased vehicle owner did not conduct due diligence while

employing a driver; which is not a condition prescribed

either in the statute or in the insurance policy, despite the


wealth of precedents. It was held so in paragraph 15, as

under: -

“15. Applying the afore-stated edicts to the case on

hand, it may be noted that the petitioner-insurance

company did not even raise the plea that the owner

of the vehicle allowed Ujay Pal to drive the vehicle

knowing that his licence was fake. Its stand was that

the accident had occurred due to the negligence of

the victim himself. Further, the insurance policy did

not require the vehicle owner to undertake

verification of the driving licence of the driver of the

vehicle by getting the same confirmed with the

RTO. Therefore, the claim of the petitionerinsurance company that it has the right to recover

the compensation from the owners of the vehicle,

owing to a willful breach of the condition of the

insurance policy, viz., to ensure that the vehicle was

driven by a licenced driver, is without pleading and

proof.”

11. Now, coming to the facts of this case, A2 was produced

by R3W1, a Clerk of the record room in Tis Hazari Court as

was pointed out by the appellant. While referring to his

deposition, the Tribunal had in paragraph 179 specifically

stated that neither the Clerk nor the Court could have seized


the driving licence at the time of accident. It is also stated in

paragraph 184 that: ‘Interestingly, the police had seized the

driving licence A2 from the driver of the Tempo issued from

Alwar, renewed on 18.04.1990 till 17.04.1993’. We would, for

the moment, assume that it is a typographical error and the

statement is that A2 was seized from the driver of the truck

itself. Even then, there is no evidence to substantiate the

seizure having been made, nor even the seizure mahazar

produced, which the police would have recorded if such

seizure had been made at the accident spot or from the

driver, later on.

12. We do not find any substance in the argument of the

respondent-insurer that a collusion can be validly inferred

since the driving licence was produced by the owner. In fact,

the owner of the truck is not an individual and is a company,

as we see from the cause title. Undisputedly, even if the tortfeasor is the driver, the liability for any negligence of the

driver rests on the owner of the vehicle, vicariously. There

can be no suspicion raised merely because the owner had

produced the driving licence before Court. It only indicates

that the owner had been diligent enough to procure the

driving licence from the driver and produce it before the

Tribunal, so as to validly raise a case for indemnification by

the insurer.

13. The office of the DTO, Gurdaspur had also issued a

certificate indicating that the driving licence No.5288 issued

in the name of the first respondent was so issued on

05.04.1991 valid from 05.04.1991 to 04.04.1994 and,

thereafter renewed from 11.08.1994 to 10.08.1997 vide entry

No.2903 dated 11.08.1994, produced along with the

additional documents by the appellant and marked before

the Tribunal as R-1.

14. The driving licence issued from the office of DTO

Gurdaspur was produced as R1W1/1 and R3W3 was a Clerk

from the office of DTO Gurdaspur who claimed that Exhibit

R1W1/1 was not issued from their office and no amount was

deposited in the name of R1 towards driving licence fees in

their office on 21.08.1990. Immediately, we have to notice that

the date 21.08.1990 has no nexus with the date of issuance of

R1W1/1, which was first issued on 05.04.1991 and the renewal

effected on 11.08.1994.

15. Further, it is to be noticed that the DL register produced

from the office of DTO Gurdaspur was full of interpolations. A

colour photograph of 1st respondent was found in the register

but the name shown was different. In cross examination, it

has come out that there were interpolations and deletions

made as against other entries too. Also on the ground of there

being no possibility of a colour photograph in the year 1990,

the High Court found collusion between the owner and the

driver. The collusion at best can be only alleged for the

production of the licence and not with respect to the

entrustment of the vehicle.

16. As has been noticed in Geeta Devi (supra) there is no

pleading or substantiation of due diligence having not been

employed at the time of entrustment. R1W1 was the

Advertising In-charge of the appellant who produced the

licence before the Court as Exhibit R1W1/1. The certificate

issued by the RTO Gurdaspur was also marked as R1 which

we referred to from the additional documents. In cross

examination, there was only a bland suggestion made to the

witness that the Directors of R2 knew that R1 possessed only

a fake driving licence. There were no questions put to the

witness, who was examined on behalf of the owner, as to the

actual entrustment of the vehicle or whether R1 was

employed regularly or temporarily and when such

employment commenced, which are crucial insofar as

proving or disproving due diligence by the owner at the time

of engagement of the driver and the entrustment of the

vehicle. As has been rightly held by the precedents above

noticed, the owner of a vehicle employing a driver can only

look at the licence produced by the person seeking

employment and is not expected to verify from the licence

issuing authority whether the licence is fake or not.

17. The insurance company from the totality of the

circumstances has to bring out the absence of due diligence

in the employment of the driver or the entrustment of the

vehicle, to prove breach by the insured, which is totally

absent in the present case. The High Court had erred in

finding that there was collusion between the employer and

the employee merely for reason of the driving licence having

been produced by the employer and the driver having not

contested the claim. The driver, as has been noticed in a

number of decisions of this Court, would have kept himself

away from the box, for fear of incriminating himself; since a

prosecution was pending against him. In any event, the

vicarious liability to satisfy the damages caused by the

negligence of the employee is on the employer, the later of

whom has to contest the matter. Not only was the driving

licence, as issued to the driver produced, but, a certificate

showing its further renewal was also produced. In fact, we

specifically notice that the renewal made is not an automatic

renewal which has to be carried out within 30 days of the

expiry of a driving licence, as per the Motor Vehicles Act and

the Rules made thereunder. Herein the validity period of the

licence, originally issued expired on 04.04.1994 and the

renewal was on 11.08.1994.

18. We find absolutely no reason to sustain the order of the

High Court, mulcting the liability on the owner of the truck.

We set aside the order of the High Court, insofar as the rights


of recovery of the award amounts granted to the insurer. The

other directions, as issued by the Tribunal and modified by

the High Court, including determination of the award

amounts would stand undisturbed.

19. The appeals stand allowed.

20. Pending application, if any, shall stand disposed of.

………….……………………. J.

 (K. VINOD CHANDRAN)

………….……………………. J.

 (N. V. ANJARIA)

NEW DELHI;

OCTOBER 08, 2025.

 

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