No Prescription, No Problem? What MAC Tribunals Really Do With Unsupported Medical Bills in Motor Accident Claims

 The short answer

The weight of judicial authority favours claimants: medical bills need not be tied to an individually traceable prescription slip to be accepted in a Motor Accident Claims Tribunal (MACT). What matters is whether the bills are referable to the period and nature of treatment, and whether they are corroborated by the claimant's oral testimony or the hospital record. The absence of a prescription is a factor the Tribunal may weigh — particularly where the insurer specifically challenges the bills or the medicines appear unconnected to the injury — but it is not, by itself, a ground for wholesale rejection.

The governing principle: linkage over paperwork

The leading formulation comes from the Punjab & Haryana High Court in Smt. Parsanni v. Shri Sube Singh, where a 60-year-old claimant with a femur fracture had her medical bills discarded by the Tribunal solely because they had "not been proved" through examination of the issuing chemist. Reversing this, the High Court held that production of bills relating to the purchase of medicines during the period of hospitalisation, coupled with the claimant's oral evidence about the purchases, "ought to be taken as sufficient proof of authentication and admissibility." The Court went further, calling the practice of insisting on chemist or doctor examination for every bill a "needless exercise" that shackles Tribunals with "unrealistic procedures," and confined such scrutiny to "extraordinary situations" where the documents are "seriously in doubt."

This reasoning has been picked up by other courts and legal-research digests tracking MACT jurisprudence, reflecting the settled understanding that proceedings under the Motor Vehicles Act are summary in character and are not to be weighed down by strict Evidence Act formalities better suited to civil trials.

Where the lack of prescription actually bites

The absence of a prescription is not treated as irrelevant — it resurfaces as one thread in a larger fabric of doubt, usually when combined with other red flags.

Rejection followed by restoration — Ezhilarasan v.K. Ravi. Here the Chennai MACT rejected medical bills worth roughly Rs. 9.36 lakh and awarded a token Rs. 1,910 instead, reasoning that "unnecessary medicines have been prescribed" and that the bills appeared inflated. On appeal, the Madras High Court directed the insurer's own counsel to physically verify the bills — and counsel candidly conceded she could not substantiate the fabrication charge. The High Court restored the full amount, along with substantially enhanced awards for attendant charges, pain and suffering, and future medical expenses. The case is a caution against tribunals discounting bills on suspicion alone: if the insurer cannot make good on a challenge once actually tested, the bills must stand.

Partial acceptance based on bill type, not prescription alone — Nagabathula Hara Gopal v. Malluri Venkata Rama Krishna. The claimant produced a mix of computerised and manually written bills covering both a leg fracture and an (unrelated) kidney ailment. The Tribunal accepted only the computerised bills and rejected the manual ones, partly reasoning that manual bills "could be manipulated" and noting that, "except a few prescriptions, the claimants have not produced prescriptions for all the bills." On appeal, the High Court agreed that bills relating to the kidney treatment were rightly excluded (since the injury itself did not support that claim), but held it was wrong to reject all manual bills wholesale — some manual bills genuinely related to the proven fracture injury — and enhanced the medical expenses award accordingly. The real driver of rejection here was the mismatch between the medical bill and the proven injury, with the prescription gap serving only as supporting, not independent, ground.

Aggregated commentary on recent Andhra Pradesh/Telangana rulings. Legal-research digests tracking 2022–2025 High Court decisions from Andhra Pradesh and Telangana note a recurring theme: where bills are produced in isolation, are internally suspicious (illegible, unrelated to the claimant, or challenged as fabricated), and are not backed by hospital records or prescriptions, courts have declined to treat mere production as proof of expenditure, insisting the claimant additionally examine the treating doctor or produce corroborating hospital documentation. This strand should be read as reinforcing, not displacing, the Parsanni principle — it operates precisely in the "seriously in doubt" category that Parsanni itself carved out as the exception.

A practical framework for adjudication

Situation	Likely tribunal approach
Bills match the hospitalisation/treatment period, are consistent with the diagnosed injury, and the claimant testifies to the purchases; no serious challenge from the insurer	Accepted despite absence of a separate prescription — bills plus oral testimony are treated as sufficient proof
Bills include medicines unconnected to the diagnosed injury (e.g., for an ailment the accident did not cause), or unexplained high quantities	Tribunal may discount or reject that specific portion as unconnected or unproven, as in the kidney-treatment bills in Nagabathula Hara Gopal
Insurer specifically alleges fabrication or inflation, citing the missing prescription as part of the pattern	Tribunal should scrutinise the claim, but rejection is sustainable only if the challenge survives actual testing — mechanical rejection risks reversal, as in Ezhilarasan
Prescriptions exist for most bills but are missing for a few	The unprescribed few may receive lesser weight while the substantiated bulk is allowed
Discharge summary or hospital record itself lists medicines administered, without a separate prescription slip	The hospital record can itself perform the corroborative function that a prescription would otherwise serve

 

Practical note for adjudication

The operative question is not "was a prescription filed?" but "are these bills reasonably referable to the treatment received for the accident injury?" — tested against the discharge summary, the treatment period, the nature of the injury, and the claimant's unshaken oral testimony. Many hospitals issue composite discharge cards listing medicines administered without generating a separate prescription document, and claimants purchasing follow-up medicines from outside pharmacies do not always retain a doctor's slip; treating this gap as fatal would penalise ordinary human behaviour rather than genuine fraud.

Rejection is more defensible where the insurer specifically challenges the bills — through cross-examination, verification, or pointing to a demonstrable mismatch between the medicine purchased and the injury sustained — and the claimant is unable to answer that challenge, or where the quantum is disproportionate to the treatment actually undergone. In such cases, the correct course is usually to disallow or reduce only the unconnected or unexplained portion, retaining the bills that align with the medical record, rather than discarding the claim wholesale. That calibrated approach, rather than an automatic prescription-matching exercise, is what the case law — from Parsanni through Ezhilarasan to Nagabathula Hara Gopal — actually supports.

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