The Supreme Court awarded sums ranging between Rs 35 and 65 lakh in compensation to the families of three teachers who lost their lives in a road accident over two decades ago on Monday (July 13).
The judgment outlined the legal principles regarding the standard of proof required in motor accident claim cases, distinguishing between civil liabilities and criminal trials.
The accident, followed by a long legal battle
On the night of January 30, 2002, a Maruti car travelling from Allahabad to Orai collided with a heavy tanker near the Sarsaul police station. Three occupants – Mata Prasad, Ajeet Singh and Roop Singh – were killed, while a fourth, Dr Dileep Kumar Katiyar, survived with severe injuries.
The families of the deceased filed claim petitions under Section 166 of the Motor Vehicles Act, 1988, which allows victims or their legal heirs to seek compensation for accidents arising out of motor vehicle accidents.
The Motor Accident Claims Tribunal in Jalaun initially dismissed their main claims, concluding that the car driver was at fault. It granted the families only a minimal amount under Section 140 of the Act, which deals with ‘no fault liability’ – a provision that provides a fixed, baseline compensation regardless of who caused the accident.
The families appealed to the Allahabad High Court, which, on August 28, 2024, affirmed the tribunal’s awards. The families then approached the Supreme Court.
Standard of proof in motor accident claims
In its judgment, the Supreme Court bench comprising Justices Sanjay Karol and Vipul M Pancholi emphasised that motor accident claims are civil proceedings, not criminal trials.
It noted, “The Tribunal is not a criminal Court and must not import the stringency of the criminal standard while evaluating civil liability arising out of motor accidents.”
In criminal cases, the prosecution must prove guilt “beyond reasonable doubt”. But in civil compensation cases, the standard of proof is the “preponderance of probabilities”, which means that a court must only decide whether it is more likely than not that an event occurred based on the evidence.
“The evidence-on-record must, therefore, be appreciated in a pragmatic manner keeping in view the object and purpose of the Motor Vehicles Act, 1988,” the court added.
Flawed evidence and a missing witness
The Supreme Court found that the tribunal and the High Court “committed a serious error” by relying on photographs submitted by the tanker owner that showed the tanker parked on the left side of the road and the car on the wrong side. The apex court bench pointed out that the owner took these pictures nearly 10 to 12 hours after the collision.
“Such photographs cannot be treated as an accurate representation of the position of the vehicles at the time of impact/accident,” the bench observed.
Instead, it emphasised the testimony of the sole surviving eyewitness, Katiyar. The bench found his testimony believable, noting that he categorically stated the car was on its correct side of the road at a controlled speed when the speeding tanker hit it from the opposite direction.
The defence had also claimed that the tanker was stationary because its conductor had gone to attend the call of nature. Yet, the conductor was never produced as a witness. The Supreme Court stated that an “adverse inference must, therefore, be drawn against the respondents for withholding the best available evidence.”
‘The thing speaks for itself’
The Supreme Court went on to invoke the legal maxim res ipsa loquitur – meaning that “the thing speaks for itself”. This principle is used in law when the very occurrence of an accident implies negligence.
The court observed that parking a heavy vehicle on a public road at night without parking lights, hazard indicators or reflective warning signs constitutes negligence in itself. “Once it is shown that a heavy vehicle was left standing on the roadway at night without adequate warning signs and a collision occurred, the burden shifts upon the respondents to establish that all reasonable precautions had been taken,” the court said. “The respondents have failed to discharge that burden.”
It also noted that the police had filed a chargesheet against the tanker driver for rash driving and causing death by negligence, which further corroborated the claimants’ version of events.
The court concluded that the findings of the tribunal and the High Court were “perverse and unsustainable in law” and calculated the compensation based on established legal precedents regarding the victims’ income and future prospects. It directed the insurance company for the tanker to pay the three families Rs 65.58 lakh, Rs 41.66 lakh and Rs 35.36 lakh, respectively, along with interest of 6 per cent per annum from the date the claim petitions were originally filed until the money is fully paid.
The families of the deceased filed claim petitions under Section 166 of the Motor Vehicles Act, 1988, which allows victims or their legal heirs to seek compensation for accidents arising out of motor vehicle accidents. 
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