Sikkim HC: Why an FIR Alone Can’t Prove Insurance Policy Breach in Motor Accident Claims?

The only evidence which the Appellants rely upon for the purpose of showing that there was a breach of a condition of the policy on the part of the insured of the vehicle having been given on hire to the deceased and her group, is the first information report lodged by Shrijana Pradhan, PW 2, who was also travelling in the same vehicle. No doubt, the statement recorded by the police of Manesar Police Station, Gurgaon, states that the vehicle was taken on hire, but this is in clear conflict with the statements made on oath before the Tribunal by the claimant No. 1 appearing as PW 1 and the maker of the F.I.R., the PW 2. It is a settled principle of law that an F.I.R. is not a substantive piece of evidence but only corroborative that can also be used for contradiction under Section 145 of the Evidence Act. The Appellants have not led any evidence at all, let alone produce evidence to prove that the vehicle was taken on hire by the deceased and her family. Therefore, the question of the F.I.R. corroborating the evidence of the insurers did not arise at all when they did not have any other evidence. The Appellant insurer also failed to confront the witness with the statement contained in the F.I.R. for the purpose of contradiction, an opportunity which was available to them under Section 145 of the Evidence Act. The Appellants could have easily produced the person who wrote down the F.I.R. as a witness to prove that the PW 2 had indeed made the statement before the police which had been denied by her in her deposition before the Tribunal. This having not been done, it is difficult for this Court to accept the contention of the insurer Appellant that the vehicle was given on hire. The sworn testimony of the witness made before the Tribunal, therefore, has to be given the necessary weight age over the one that is unsworn, and in this case unsigned statement, recorded by the police which in any case has only a corroborative value.

 IN THE HIGH COURT OF SIKKIM AT GANGTOK

M.A.C. Appeal No. 3 of 2009

Decided On: 17.05.2010

Branch Manager, Oriental Insurance Co. Ltd. and Ors. Vs. M.K. Subba and Ors.

Hon'ble Judges/Coram:

Sonam Phintso Wangdi, Actg. C.J.

Citation: 2011AIR Sikkim 28,2011 ACJ 1482, MANU/SI/0040/2010.

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Supreme Court: How to appreciate evidence in motor accident claim petition if initially offence was registered against unknown vehicle?

 The very fact that the case was registered against an unknown vehicle initially would indicate that the offending vehicle was not identified. However, since an FIR is not expected to be encyclopaedic2 and is only for the purpose of putting into motion criminal law such that thorough and full-fledged investigation by the police ensues, it is the duty of the investigating agency to find out the identity of the culprit which in the present case would be the offending car and driver and take action in accordance with law. Thus, the mere fact that initially the FIR records the vehicle as unknown would not be fatal for the prosecution/claimants to later come up with the specific identity of the vehicle/driver, with the obvious caveat that the connection of the accident with the said vehicle has to be based on cogent and reliable evidence. {Para 17}

Ratio: The Supreme court highlighted that the initial identification of the vehicle as "unknown" does not render the prosecution's case fatal, as long as reliable evidence can later establish the identity of the vehicle involved in the accident.

 IN THE SUPREME COURT OF INDIA

Civil Appeal No. 5029 of 2025.

Decided On: 07.04.2025

Kuncham Lavanya and Ors. Vs. Bajaj Allianz General Insurance Co. Ltd. and Ors.

Hon'ble Judges/Coram:

Sudhanshu Dhulia and Ahsanuddin Amanullah, JJ.

Author: Ahsanuddin Amanullah, J.

 Citation: 2025 INSC 452,MANU/SC/0462/2025

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Important Judgments for appreciation of evidence which shows that claimant has filed false motor vehicle cases

 

1) Bombay HC: How to appreciate evidence in motor accident claim petition when false case is put forth by claimant?

Therefore, if he was an eye witness to the incident, why he did not inform the said fact and ask the police to incorporate the vehicle number of Tata Magic in the inquest panchnama itself, is also a question. Conveniently the claimants have kept him out of witness box, for the reasons best known to them. Therefore, mere mention of Tata Magic in inquest panchnama will not be sufficient to hold that it was the Tata Magic belonging to respondent No. 1 and insured with respondent No. 2 on the date of the accident.

IN THE HIGH COURT OF BOMBAY (AURANGABAD BENCH)

First Appeal No. 606 of 2019 and Civil Application No. 3025 of 2019 in FA/606/2019

Decided On: 24.09.2019

Shriram Insurance Company Ltd. Vs. Vanita and Ors.

Hon'ble Judges/Coram:

Vibha Kankanwadi, J.

Citation: MANU/MH/2654/2019.

https://www.lawweb.in/2025/05/bombay-hc-how-to-appreciate-evidence-in.html

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Karnatka HC: How to ascertain that claimant has filed false motor accident claim petition?

One Satish was examined as P.W. 2 in support of the claim. He claimed to have witnessed the accident. He has stated that the accident was due to rash and negligent driving of the car referred to above. He had not given any complaint to the police. He did not take the injured persons to the hospital. Though he claimed to have given statement before the police, neither such statement was produced, nor the police were examined to prove it. In the charge sheet, he is not even named as a witness. This coupled with the other facts shows that he had not witnessed the accident. {Para 4}

5. In Ex. P3 (seizure mahazar) prepared by the police on 24.03.2008, it is stated that the bumper of the car was damaged. But in the motor vehicle Inspector's report (Ex. P5) which was also prepared on the same day i.e. on 24.03.2008, it is stated that there was no damage to the car. This shows that the police had fabricated the criminal case.

8. When involvement of the insured vehicle in the accident is disputed, it is for the claimants to place acceptable evidence to prove its involvement and to prove that the accident arose out of use of the insured vehicle. If the claim is based on fault, then negligent user of the vehicle also requires to be proved. 

9. Fraudulent claims are on the rise. Hence, it is necessary to state that, filing of complaint to the police, or filing of charge sheet by the police, by itself, is no proof of involvement of the vehicle in the accident. Delayed filing of complaint to the police by giving particulars of a vehicle stating that it is involved in the accident, or delayed noting of particulars of a vehicle in the police record is prima facie indicative of its false implication in the accident. In such cases, stricter scrutiny of the evidence is required. The evidence requires to be assessed with great care and caution. The main test is one of reliability.

 IN THE HIGH COURT OF KARNATAKA AT BENGALURU

Miscellaneous First Appeal No. 7025/2011 (MV)

Decided On: 09.11.2015

Arathy and Ors. Vs. S.M. Umesha and Ors.

Hon'ble Judges/Coram:

H.G. Ramesh, J.

Citation: 2015:KHC:32692, MANU/KA/4733/2015.

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Bombay HC: What will be effect of non examination of investigating officer by claimant in motor accident claim petition?

The claimants are also relying on statement

of   respondent   no.01   dated   10­07­2014   recorded   by

police.     The   said   statement   appears   to   be   part   of

charge­sheet   of   which   certified   copy   had   been

produced.     The   said   statement   has   been   taken   as

statement of the accused and therefore, for criminal

case,   it   may   not   be   admissible   in   evidence.     As

regards   civil   case   is   concerned,   no   doubt,   the

question   arises   as   to   whether   in   absence   of

examination   of   the   person   who   had   recorded   it,

whether it can be read in evidence, that too, without

deciding whether certified copy of such statement can

be   read   in   evidence.     It   appears   that   from   this

angle, submissions were not made before the Tribunal.

Even if for the sake of arguments, we take the said

statement   as   it   is,   in   which   it   was   stated   by

respondent   no.01,   that   due   to   the   dash   of   his

motorcycle   to   the   motorcycle   driven   by   deceased,

deceased   as   well   as   his   pillion   rider   fell   down;

statement   is   made   that   after   they   had   sustained

injuries,   he   immediately   asked   Ratnakar   and   Ganesh,

as to what is their name and then came to know about

their names and then he had called some other persons

and made arrangements for medical help.   That means,

he   intended  to   say  that  Ratnakar   as  well   as  Ganesh

were   conscious   when   he   made   enquiries   with   them.

This is contrary to what has been stated in the FIR.

In the FIR, it is stated that after they fell down

from the motorcycle after the dash, they had raised

hue and cry; however, motorcycle rider did not stop

and   fled   away.     Under   such   circumstance,   how   the

claimants can rely on his statement, is a question,

rather   it   gives   an   example   as   to   how   the   vehicle

belonging   to   respondent   no.02   has   been   involved   in

the case.   Ultimately, respondent no.01 says that he

will not be able to say how the accident took place

and   who   was   at   fault.     Therefore,   the   alleged

connection   between   the   medical   examination   of

respondent   no.01   and   the   accidental   injuries   caused

due   to   the   accident,   cannot   be   said   to   have   been

established   merely   by   producing   the   injury

certificate as well as statement of respondent no.01

taken by police.   The police head ­constable who had

taken   his   statement,   has   not   been   examined   by   the

claimants for the reasons best known to them. {Para 11}

12. The charge­sheet also contains statement of

respondent no.02 which is alleged to have been taken

on   07­-07­-2014,   who   has   echoed   thereafter   with

claimant   no.03   Ganesh   and   then   has   stated   that

respondent   no.01   had   carried   out   repairs   to   his

motorcycle   and   then   handed   it   over   to   respondent

no.02.   Again, at the cost of repetition, it can be

said that without examining the said police constable

who had recorded statement of respondent no.02, his

statement   cannot   be   considered.     This   is   with   the

fact,   that   in   their   written   statement,   respondents

no.01 and 02 have clearly denied involvement of the

motorcycle   bearing   no.   MH­17/AY­9996   in   the   said

accident. 

13. Again,   coming   to   the   point   regarding   delay

in lodging the FIR, it can be seen that the fact of

death   of   Ratnakar   was   informed   to   police   and

thereafter enquiry under Section 174 of the Code of

Criminal Procedure was conducted wherein the inquest

panchanama was carried out and then the dead body was

sent for post mortem.  Important point to be noted is

that when on that day i.e. on the day when inquest

panchanama  was prepared, there was an opportunity to

the  claimants  or  on  behalf   of  them,  FIR  could  have

been   lodged   against   unknown   vehicle.     Same   has   not

been  done.    Whatever   FIR  has   been  lodged   on  23­-04­-

2014,   is   also   against   unknown   person.     Therefore,

this   clear   delay   in   lodging   the   FIR   and   then   not

examining the police constable who had recorded the

statements   of   respondents   no.01   and   02   or   the

Investigation   Officer,   is   required   to   be   viewed

against the claimants.  

IN THE HIGH COURT OF JUDICATURE AT BOMBAY,

  AURANGABAD BENCH, AT AURANGABAD.    

First Appeal No. 0186 of 2019     

Kavita Ratnakar Ghodke, Vs   Sandip Sarjerao Jadhav,

 CORAM : SMT. VIBHA KANKANWADI, J.

  DATE  : 15TH JULY 2019.

Read full judgment here: Click here. 

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Bombay HC: What will be effect of delay in lodging of police report in motor accident claim petition?

 Again,   coming   to   the   point   regarding   delay

in lodging the FIR, it can be seen that the fact of

death   of   Ratnakar   was   informed   to   police   and

thereafter enquiry under Section 174 of the Code of

Criminal Procedure was conducted wherein the inquest

panchanama was carried out and then the dead body was

sent for post mortem.  Important point to be noted is

that when on that day i.e. on the day when inquest

panchanama  was prepared, there was an opportunity to

the  claimants  or  on  behalf   of  them,  FIR  could  have

been   lodged   against   unknown   vehicle.     Same   has   not

been  done.    Whatever   FIR  has   been  lodged   on  23­-04­-

2014,   is   also   against   unknown   person.     Therefore,

this   clear   delay   in   lodging   the   FIR   and   then   not

examining the police constable who had recorded the

statements   of   respondents   no.01   and   02   or   the

Investigation   Officer,   is   required   to   be   viewed

against the claimants.  {Para 13}

14. No   doubt,   Motor   Vehicles   Act,   1988,   is   a

beneficial   legislation;   but   then   liberal

interpretations   and   benefit   can   be   given   when   the

accident   is   proved.     When   accident   itself   is   not

proved, though the burden was on the claimants; then

question   of   liberal   interpretation   does   not   arise.

The   point   no.   I   is,   therefore,   answered   in   the

negative.

IN THE HIGH COURT OF JUDICATURE AT BOMBAY,

  AURANGABAD BENCH, AT AURANGABAD.    

First Appeal No. 0186 of 2019     

Kavita Ratnakar Ghodke, Vs   Sandip Sarjerao Jadhav,

 CORAM : SMT. VIBHA KANKANWADI, J.

  DATE  : 15TH JULY 2019.

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Bombay HC: How to appreciate evidence in motor accident case when police report was lodged against unknown vehicle?

 The burden of proof is on the claimants. Same may be discharged on preponderance of probabilities. The insurer may lead independent evidence in disproof of the claim or it may point out that the evidence relied on is inherently improbable and the Tribunal, therefore, ought not to have acted on it. {Para 14}

15. The Tribunal, in the present case, has simply relied on the factum of filing of charge sheet against the tractor driver. Admittedly, the report of the accident was lodged against unknown vehicle. It is only after three weeks a person comes forward claiming to have had witnessed the accident. He recalled of the accident only on having seen the hoarding depicting the picture of the deceased - Sandip. According to the alleged eye witness, some person had gathered on the spot of accident. Had it really been so, involvement of the offending tractor could have come to light immediately, i.e., on the same day of the accident. Same suggests that no person had witnessed the accident. The conduct of the alleged eye witness - Atul Gade in coming forward after three weeks of the accident, is unnatural and does not stand to reason. He was residing at a nearby village. On having seen such an accident, he left the place without intimating the same to anyone else. Realising to have had witnessed the accident only on having seen the hoarding and picture of the deceased, leads this Court to observe that this person is a got up witness only with a view to earn the compensation. This Court is, therefore, not inclined to rely on the evidence of this witness.

16. There is no other evidence in proof of involvement of the tractor in question. The Tribunal ought not to have allowed the claim petition merely relying on such police papers namely, charge-sheet, seen of accident panchnama and post mortem notes. This Court has, therefore, every reason to interfere with the impugned judgment and award. In view of this Court, the evidence fell short to make out case even on preponderance of probabilities.

IN THE HIGH COURT OF BOMBAY (AURANGABAD BENCH)

First Appeal No. 1342 of 2021

Decided On: 31.01.2022

Shriram General Insurance Company Ltd. Vs. Tilottam and Ors.

Hon'ble Judges/Coram:

R.G. Avachat, J.

Citation:  MANU/MH/1303/2022.

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Bombay HC: How to appreciate evidence in motor accident claim petition when false case is put forth by claimant?

As regards the fact of accident is concerned, the initial burden is always on the claimant/ claimants to prove the same, which includes not only the involvement of the vehicle but also the manner in which the accident had taken place, as pleaded in the petition. All those authorities, which have been relied by the learned Advocate appearing for the appellant, have reiterated the basic principle as aforesaid i.e. the burden is on the claimants to prove the accident including the involvement of the vehicle/vehicles. In First Appeal No. 2742 of 2015 (supra) note has been taken of the decision of Division Bench of this Court in First Appeal No. 32 of 2013 decided on 11.07.2013 (Goa Bench), wherein it was held that mere production of police papers and exhibiting those documents does not dispense the proof of contents of those documents. It was also held that merely on the basis of certified copies of First Information Report, Spot Panchnama and other documents the claimants cannot prove their case. Therefore, it is now required to be seen, as to whether the evidence adduced in this case fulfills the criteria.

12. The First Information Report has been admittedly lodged belatedly. At this stage itself, note can be taken regarding the ratio in Ravi v/s. Badrinarayan and others reporting in MANU/SC/0133/2011 : (2011) 4 SCC 693 that delay in lodging the FIR, cannot be taken as a main ground for rejecting the claim petition. Here not only the point of delay has been canvassed but it is coupled with non-involvement and collusion. Therefore, facts and evidence is required to be scanned taking into consideration these aspects. Informant Balaji is the brother of deceased and in the First Information Report, which has been lodged after 25 days of accident (on 21.06.2011), number of Tata Magic has been given and then it is stated that when he came to know about the accident, he went to hospital, where Dhanaji was admitted. He had come to know that two persons from his village viz. Laxman Uttam Kamble and Mahesh Rangnath Deshmukh had admitted Dhanaji to hospital regarding details of accident. It appears that Dhanaji was unconscious on that day but on the next day i.e. on 28.05.2011 he expired at about 1.00 p.m.. It also appears from the contents of the First Information Report that the police were calling Balaji, since the date of post mortem and inquest panchnama, to lodge First Information Report but Balaji had not gone to Police Station. He has tried to explain that, since he was in grief and his mental condition was not proper, inspite of messages given he could not lodge the report. The claimants have not examined Balaji for the reasons best known to them. No doubt, he was not eye witness but then he could have thrown light as to why he had lodged the First Information Report belatedly and no other person could have lodged the report at any earlier point of time. Interesting point to be noted is that the inquest panchnama was executed on 28.05.2011 when Balaji was present. The inquest panchnama Exh.32 only makes a statement that motorcycle driven by Dhanaji was dashed by Tata Magic. Why First Information Report was not taken down at that point itself is a question. It will not be out of place to mention another interesting fact that claimants have examined CW 2 Dipak Lokhande, whose name is not appearing in inquest panchnama or in the spot panchnama or even in First Information Report, but then he say that he had seen the accident. So also, he says that the accident was witnessed by Laxman Kamble and Mahesh Deshmukh from his village. Now said Mahesh Deshmukh is, in fact, panch to the inquest panchnama. Therefore, if he was an eye witness to the incident, why he did not inform the said fact and ask the police to incorporate the vehicle number of Tata Magic in the inquest panchnama itself, is also a question. Conveniently the claimants have kept him out of witness box, for the reasons best known to them. Therefore, mere mention of Tata Magic in inquest panchnama will not be sufficient to hold that it was the Tata Magic belonging to respondent No. 1 and insured with respondent No. 2 on the date of the accident.

IN THE HIGH COURT OF BOMBAY (AURANGABAD BENCH)

First Appeal No. 606 of 2019 and Civil Application No. 3025 of 2019 in FA/606/2019

Decided On: 24.09.2019

Shriram Insurance Company Ltd. Vs. Vanita and Ors.

Hon'ble Judges/Coram:

Vibha Kankanwadi, J.

Citation: MANU/MH/2654/2019.

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How to appreciate evidence in motor accident claim petition?

 Unfortunately, this Court finds that the said well considered decision of the Tribunal was set aside by the High Court, inter alia, on the ground that even though complaint was forwarded to SSP Hisar and was further forwarded to SSP Hanumangarh but none from the office of SSP, Hanumangarh came to prove the complaint. The filing of the complaint by the Appellant is not disputed as it appears from the evidence of PW.3-Satbir Singh, who is the Assistant Complaint Clerk in the office of Superintendent of Police, Hisar. If the filing of the complaint is not disputed, the decision of the Tribunal cannot be reversed on the ground that nobody came from the office of SSP to prove the complaint. The official procedure in matters of proceeding with the complaint is not within the control of the Appellant, who is an ordinary village woman. She is not coming from the upper echelon of society. The general apathy of the administration in dealing with complaints lodged by ordinary citizens is far too well known to be overlooked by High Court. In this regard the perception of the High Court in disbelieving the complaint betrays a lack of sensitized approach to the plight of a victim in a motor accident claim case. {Para 10}

11. The other ground on which the High Court dismissed the case was by way of disbelieving the testimony of Umed Singh-PW.1. Such disbelief of the High Court is totally conjectural. Umed Singh is not related to the Appellant but as a good citizen, Umed Singh extended his help to the Appellant by helping her to reach the Doctor's chamber in order to ensure that an injured woman gets medical treatment. The evidence of Umed Singh cannot be disbelieved just because he did not file a complaint himself.

12. We are constrained to repeat our observation that the total approach of the High Court, unfortunately, was not sensitized enough to appreciate the plight of the victim.

The other so-called reason in the High Court's order was that as the claim petition was filed after four months of the accident, the same is "a device to grab money from the insurance company". This finding in the absence of any material is certainly perverse. The High Court appears to be not cognizant of the principle that in a road accident claim, the strict principles of proof in a criminal case are not attracted.

The following observations of this Court in Bimla Devi and Ors. v. Himachal Road Transport Corporation and Ors.   MANU/SC/0577/2009 : (2009) 13 SCC 530 are very pertinent.

In a situation of this nature, the Tribunal has rightly taken a holistic view of the matter. It was necessary to be borne in mind that strict proof of an accident caused by a particular bus in a particular manner may not be possible to be done by the claimants. The claimants were merely to establish their case on the touchstone of preponderance of probability. The standard of proof beyond reasonable doubt could not have been applied.

 IN THE SUPREME COURT OF INDIA

Civil Appeal No. 1082 of 2011

Decided On: 28.01.2011

Parmeshwari Vs. Amir Chand and Ors.

Hon'ble Judges/Coram:

G.S. Singhvi and A.K. Ganguly, JJ.

Author: A.K. Ganguly, J.

Citation:  MANU/SC/0358/2011,(2011) 11 SCC 635.

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Landmark Supreme Court Judgment on appreciation of evidence in the case of Motor accident claim petition

 In a situation of this nature, the Tribunal has rightly taken a holistic view of the matter. It was necessary to be borne in mind that strict proof of an accident caused by a particular bus in a particular manner may not be possible to be done by the claimants. The claimants were merely to establish their case on the touchstone of preponderance of probability. The standard of proof beyond reasonable doubt could not have been applied.

(emphasis supplied) {Para 15}

19. The failure of the Respondents to cross examine the solitary eyewitness or confront him with their version, despite adequate opportunity, must lead to an inference of tacit admission on their part. They did not even suggest the witness that he was siding with the claimants. The High Court has failed to appreciate the legal effect of this absence of cross-examination of a crucial witness.

21. Relying upon Kartar Singh (supra), in a MACT case this Court in Sunita v. Rajasthan State Road Transport Corporation considered the effect of non-examination of the pillion rider as a witness in a claim petition filed by the deceased of the motorcyclist and held as follows:

30. Clearly, the evidence given by Bhagchand withstood the Respondents' scrutiny and the Respondents were unable to shake his evidence. In turn, the High Court has failed to take note of the absence of cross examination of this witness by the Respondents, leave alone the Tribunal's finding on the same, and instead, deliberated on the reliability of Bhagchand's (A.D. 2) evidence from the viewpoint of him not being named in the list of eye witnesses in the criminal proceedings, without even mentioning as to why such absence from the list is fatal to the case of the Appellants. This approach of the High Court is mystifying, especially in light of this Court's observation [as set out in Parmeshwari (supra) and reiterated in Mangla Ram (supra)] that the strict principles of proof in a criminal case will not be applicable in a claim for compensation under the Act and further, that the standard to be followed in such claims is one of preponderance of probability rather than one of proof beyond reasonable doubt. There is nothing in the Act to preclude citing of a witness in motor accident claim who has not been named in the list of witnesses in the criminal case. What is essential is that the opposite party should get a fair opportunity to cross examine the concerned witness. Once that is done, it will not be open to them to complain about any prejudice caused to them. If there was any doubt to be cast on the veracity of the witness, the same should have come out in cross examination, for which opportunity was granted to the Respondents by the Tribunal.

22. Equally, we are concerned over the failure of the High Court to be cognizant of the fact that strict principles of evidence and standards of proof like in a criminal trial are inapplicable in MACT claim cases. The standard of proof in such like matters is one of preponderance of probabilities, rather than beyond reasonable doubt. One needs to be mindful that the approach and role of Courts while examining evidence in accident claim cases ought not to be to find fault with non-examination of some best eye-witnesses, as may happen in a criminal trial; but, instead should be only to analyze the material placed on record by the parties to ascertain whether the claimant's version is more likely than not true. 

23. The observation of the High Court that the author of the FIR (as per its judgment, the owner-cum-driver) had not been examined as a witness, and hence adverse inference ought to be drawn against the Appellant-claimants, is wholly misconceived and misdirected. Not only is the owner-cum-driver not the author of the FIR, but instead he is one of the contesting Respondents in the Claim Petition who, along with insurance company, is an interested party with a pecuniary stake in the result of the case. If the owner-cum-driver of the car were setting up a defence plea that the accident was a result of not his but the truck driver's carelessness or rashness, then the onus was on him to step into the witness box and explain as to how the accident had taken place. The fact that Sanjeev Kapoor chose not to depose in support of what he has pleaded in his written statement, further suggests that he was himself at fault. The High Court, therefore, ought not to have shifted the burden of proof.

 IN THE SUPREME COURT OF INDIA

Civil Appeal Nos. 4010-4011 of 2020 

Decided On: 08.12.2020

Anita Sharma and Ors. Vs. The New India Assurance Co. Ltd. and Ors.

Hon'ble Judges/Coram:

Surya Kant and Aniruddha Bose, JJ.

Author: Surya Kant, J.

Citation: MANU/SC/0928/2020,(2021) 1 SCC 171.

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