MP HC: Medicine bills filed in motor accident claim petition cannot be said to be authentic and genuine without there being any seal or GST/Sales Tax number

After hearing learned counsel for the parties and going through the record, when this Court wanted to know from Shri Kapil Patwardhan that there are several bills of purchase of medicines from one 'Maa Pharmacy' starting from Exhibit P-11 to Exhibit P-108 and none of them bears GST number or seal of Maa Pharmacy, then how these bills are admissible in evidence, He has no answer to this query of the Court. {Para 4}

12.  Similarly, bills from Ex P-11 to Ex.P-108 are also required to be deducted from the amount awarded by the tribunal, inasmuch as, these bills cannot be said to be authentic and genuine without there being any seal or GST/Sales Tax number. Shri Rakesh Jain submits that the claimant has produced bills of Rs.91,607/- for purchase of medicines from Maa Pharmacy.

IN THE HIGH COURT OF MADHYA PRADESH (JABALPUR BENCH)

Misc. Appeal No. 565 of 2022

Decided On: 13.03.2025

Shriram General Insurance Company Ltd. Vs. Rakesh Valtiya and Ors.

Hon'ble Judges/Coram:

Vivek Agarwal, J.

Citation: 2025:MPHC-JBP:12927, MANU/MP/0988/2025

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Injury, Not Blame: Proving “Grievous Hurt” in a No-Fault Claim under Section 164 of the Motor Vehicles Act

 The governing idea

Section 164 of the Motor Vehicles Act, 1988 creates a fixed-compensation, no-fault remedy. In an injury claim, the central questions are not who drove negligently or who was responsible for the collision, but whether: (i) an accident arose out of the use of the vehicle concerned; (ii) the claimant sustained bodily injury because of that accident; and (iii) the injury legally qualifies as “grievous hurt.” On proof of those foundational facts, the owner or authorised insurer is liable to pay the statutory sum of ₹2,50,000; Section 164(2) expressly relieves the claimant of proving any wrongful act, neglect or default.

This distinction may be expressed in one sentence:

Vehicle involvement and causal connection must be proved; fault and blame need not be proved.

That is the conceptual dividing line. Section 164 of motor vehicle Act dispenses with an inquiry into negligence, but it does not dispense with proof that the identified motor vehicle was involved in an accident arising out of its use and that the accident caused a legally recognised grievous hurt.

Why Section 164 of motor vehicle Act matters

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Supreme Court: S 156(3) CrPC Order Is Pre-Cognizance Step, Sanction Under S 197 CrPC Not Required At That Stage

 The scheme of CrPC does not contemplate any embargo on the direction for registration of an FIR or the conduct of investigation at the pre-cognizance stage. To hold otherwise would amount to introducing a restriction not envisaged by the legislature. The process of criminal law is sequential: information of a cognizable offence must first be received; an FIR must then be registered; investigation must follow; a report under Section 173 of CrPC must thereafter be submitted; and it is only at that stage that the question of taking cognizance arises. {Para 126}

127. The requirement of sanction is, therefore, a condition precedent only for taking cognizance and not for the registration of an FIR or for the conduct of investigation. Any interpretation that makes the registration of an FIR contingent upon prior sanction would invert this statutory scheme and render the provisions relating to investigation unworkable.

129. The bar under Sections 196 and 197 of CrPC would operate

only in respect of the latter course. It could not have been invoked to deny the former. The Trial Court, therefore, fell in error in declining to exercise jurisdiction under Section 156(3) of CrPC on the ground of absence of prior sanction, and the High Court, in affirming such view, has adopted an interpretation which cannot be sustained in law.” [Emphasis supplied]

28. Thus, it is clear that the impugned order, insofar as it extends the benefit of the protective umbrella of sanction to the respondents at the stage of direction for registration of FIR under Section 156(3) CrPC, is per se unsustainable in the eyes of law.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO(S). OF 2026

(Arising out of SLP(Crl.) No(s). 1137 of 2025)

SRI ANUMANDALA RAJESH REDDY Vs STATE OF KARNATAKA AND ANR. 

Author: Mehta, J.

Citation: 2026 INSC 1039.

Dated: AUGUST 24, 2026.

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Supreme Court permitted a mother to relocate her two minor children to the United Kingdom, while denying custody to the father who is facing prosecution under Pocso Act

 These principles, read together, make it clear

that the son’s disclosure and his safety cannot be

subordinated to the father’s claim for custody

particulars when the criminal case is still pending.

Under no circumstances, the respondent-father, as

long as he is facing prosecution, can be considered to

be a person entitled to custody of the children. Such

a course of action, apart from being contrary to the

solemn object of the Juvenile Justice Act, may also

lead to the prosecution being frustrated, inasmuch

as, were the custody of the son to be handed to the

respondent-father, the possibility of the son giving a

free and fair deposition in those proceedings would

virtually be negligible. {Para 56}

57. We are of the considered view that, even

assuming the respondent-father succeeds in the

quashing petition pending before the High Court of

Calcutta and the criminal proceedings arising out of

the POCSO FIR are quashed, the Courts would have

to remain circumspect in assessing the

circumstances and background in which the

allegations came to be levelled by the son against the

respondent-father. The subsequent outcome of the

criminal proceedings, by itself, cannot efface the

circumstances in which the disclosure was made or

render the child’s apprehensions wholly irrelevant for

the purposes of determining his welfare and custody.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NO(S). 12774 OF 2026

DEBARATI BHUNIA CHAKRABORTY  Vs

SUMAN SANKAR BHUNIA 

Author: Mehta, J.

Citation: 2026 INSC 1043.

Dated: SEPTEMBER 23, 2026.

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