A) ABSTRACT / HEADNOTE

The Supreme Court in this case overturned the findings of the Motor Accident Claims Tribunal (MACT) and the High Court, which had dismissed the appellants’ claim for compensation related to a fatal motor accident. The appellants, comprising the deceased’s widow, child, and parents, alleged that the accident occurred due to the negligent driving of a car owned by Respondent No. 1, driven by Respondent No. 2, and insured by Respondent No. 3. The Tribunal and the High Court held that the appellants failed to prove the involvement of the car in the accident. However, the Supreme Court found that the evidence, tested on the principles of preponderance of probability, established the car’s involvement. The Court directed an award of compensation of Rs. 46,31,496/- to the appellants, with interest, noting errors in the lower courts’ evaluation of evidence and their application of legal standards.

Keywords: Motor Accident, Negligence, Compensation, Preponderance of Probability, Eyewitness Credibility.

B) CASE DETAILS

i. Judgement Cause Title:
Sajeena Ikhbal & Ors. v. Mini Babu George & Ors.

ii. Case Number:
Civil Appeal No. 7881 of 2024

iii. Judgement Date:
October 17, 2024

iv. Court:
Supreme Court of India

v. Quorum:
C.T. Ravikumar and Prashant Kumar Mishra, JJ.

vi. Author:
Justice Prashant Kumar Mishra

vii. Citation:
[2024] 10 S.C.R. 786

viii. Legal Provisions Involved:

• Article 136 of the Constitution of India
• Principles of Preponderance of Probability

ix. Judgments Overruled by the Case:
Findings of the Kerala High Court in MACA No. 3331 of 2016 and the MACT.

x. Case is Related to Which Law Subjects:
Civil Law, Motor Accident Claims, Insurance Law.

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appellants challenged the findings of the MACT and the Kerala High Court, which dismissed their claim for compensation due to the death of Ikhbal, alleging the car’s involvement in the fatal accident. The Tribunal assessed the compensation amount but ruled against the appellants on evidentiary grounds. The Supreme Court reexamined these findings under Article 136, citing principles of preponderance of probability as the governing standard in motor accident cases.

D) FACTS OF THE CASE

Ikhbal, the deceased, was riding his motorcycle on June 10, 2013, near Muttom when a car allegedly driven by Respondent No. 2 hit him, causing fatal injuries. The car, owned by Respondent No. 1 and insured by Respondent No. 3, was disputed as the vehicle involved in the accident. Respondents denied negligence and the car’s involvement, attributing the accident to the deceased’s attempt to overtake a bus. The appellants sought compensation of Rs. 46,31,496/-, asserting the car’s culpability.

E) LEGAL ISSUES RAISED

1. Whether the MACT and High Court erred in concluding that the car was not involved in the accident.
2. Whether the principles of preponderance of probability apply to motor accident cases.
3. Whether the appellants were entitled to compensation under the Motor Vehicles Act.

F) PETITIONER/APPELLANT’S ARGUMENTS

i. Negligent Driving:
The appellants contended that the car was negligently driven by Respondent No. 2, causing the accident. They relied on the testimony of PW-6, an eyewitness, and the damage recorded in the Mahazar report.

ii. Evidence Misinterpretation:
Counsel argued that the courts below ignored crucial evidence, including the deposition of witnesses and physical damage to the car, which corroborated the appellants’ claim.

iii. Preponderance of Probability:
It was emphasized that claim cases should be evaluated on preponderance of probability rather than beyond reasonable doubt.

G) RESPONDENT’S ARGUMENTS

i. Non-Involvement of the Car:
Respondents argued that the accident was caused by the deceased overtaking a stationary bus. They denied that the car was involved in the collision.

ii. Eyewitness Credibility:
Respondents questioned the reliability of PW-6, as his statement was not recorded during the police investigation.

iii. Judicial Consistency:
They defended the concurrent findings of the MACT and High Court as being based on sound evidentiary principles.

H) JUDGEMENT

a. Ratio Decidendi

1. Principle of Preponderance of Probability:
   The Supreme Court held that the lower courts wrongly applied the standard of proof beyond reasonable doubt in dismissing the claim. In motor accident cases, preponderance of probability suffices.

2. Credibility of Eyewitness (PW-6):
   The Court ruled that a trustworthy eyewitness cannot be disbelieved solely because their statement was not recorded during the police investigation.

3. Relevance of Physical Evidence:
   Damage recorded in the Mahazar confirmed the car’s involvement, which the lower courts failed to appreciate.

b. Obiter Dicta

The Court noted the importance of correctly interpreting evidence in motor accident claims to avoid unjust outcomes. It emphasized fairness in applying legal principles like res ipsa loquitur.

c. Guidelines

1. In claim cases, apply the preponderance of probability standard.
2. Evaluate all evidence, including physical damage and credible witness testimony.
3. Avoid relying solely on procedural deficiencies in police investigations.

I) CONCLUSION & COMMENTS

The Supreme Court’s decision underscores the need for a victim-centric approach in motor accident cases. By highlighting the evidentiary missteps of the MACT and High Court, the judgment reiterates the primacy of substantive justice over procedural formalities.

J) REFERENCES

a. Important Cases Referred:

1. Mangla Ram v. Oriental Insurance Co. Ltd. [2018] 5 SCR 287: (2018) 5 SCC 656.

b. Important Statutes Referred:

1. Article 136 of the Constitution of India.