The Chhattisgarh High Court has reaffirmed that motor accident compensation claims are governed by civil standards of proof, not the stringent criminal threshold of beyond reasonable doubt. This ruling clarifies the evidentiary burden on claimants and insurers alike, reinforcing that insurers cannot evade liability merely by casting doubt on accident circumstances without affirmative evidence of collusion or fabrication.
Background & Facts
The Dispute
On 1 March 2020, Chandrashekhar Matari, aged 30, was fatally crushed by a tractor (registration CG-22-AB-6643) while removing straw from its front wheel. The driver, Vikas Bhoi, allegedly started the vehicle without ensuring his safety, resulting in immediate death. The incident occurred in a rural setting with no formal surveillance, and the only eyewitnesses were Kiran Dhubal and Chandramani Bhoi. The police registered Crime No. 281/2020 under Section 304-A IPC against the driver.
Procedural History
- March 2020: Accident occurred; FIR filed by Sulochana Matari (deceased’s sister-in-law), claiming Chandrashekhar fell from the tractor.
- 2021: Claimants (widow, three minor children, and parents) filed compensation petition before the Motor Accident Claims Tribunal (MACT), Raipur, seeking ₹39.5 lakh.
- November 2024: MACT awarded ₹14,65,200 against the insurer, holding the driver negligent and the insurer liable under the policy.
- 2025: Appellant-insurer appealed to the Chhattisgarh High Court, challenging the Tribunal’s reliance on oral testimony over the FIR.
Relief Sought
The appellant sought to set aside the award, arguing that the FIR and insurance intimation contradicted the claimants’ version, and that the driver lacked a valid license. The claimants sought affirmation of the award, asserting the insurer failed to rebut the preponderance of evidence establishing negligence.
The Legal Issue
The central question was whether motor accident compensation claims require proof beyond reasonable doubt, or whether the standard of preponderance of probability suffices to establish liability, even when conflicting documentary and oral evidence exist.
Arguments Presented
For the Appellant
The insurer contended that the FIR and initial intimation to the insurer stated Chandrashekhar fell from the tractor, not that he was crushed while working. It argued that Kiran Dhubal’s testimony was unreliable due to delay in recording and lack of corroboration. The insurer relied on State v. Accused to assert that discrepancies in eyewitness accounts invalidate claims. It further claimed the driver lacked a valid license, triggering policy exclusion under Section 146 of the Motor Vehicles Act.
For the Respondent
The claimants argued that the FIR was filed by a non-eye-witness and was not a reliable account of the incident. They emphasized that the insurer failed to examine the second eyewitness, Chandramani Bhoi, despite having opportunity. They cited Geeta Dubey v. United India Insurance Co. Ltd. to assert that the burden shifts to the insurer to prove collusion or fabrication, which it failed to do.
The Court's Analysis
The Court examined the jurisprudence established by the Supreme Court in Rajwati @ Rajjo v. United India Insurance Co. Ltd., Mangla Ram v. Oriental Insurance Co. Ltd., and Geeta Dubey v. United India Insurance Co. Ltd. It held that motor accident claims are civil proceedings, and the standard of proof is preponderance of probability, not beyond reasonable doubt. The Court emphasized that claimants are not required to prove the accident with forensic precision, especially in rural settings where documentation is scarce.
"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."
The Court noted that the insurer’s reliance on the FIR was misplaced, as it was filed by a non-witness and contained a version inconsistent with the eyewitness account. The Tribunal was justified in preferring the testimony of Kiran Dhubal, who was examined and stood firm under cross-examination. Crucially, the insurer failed to examine Chandramani Bhoi, the second eyewitness, despite having the means to do so. The Court held that this omission was fatal to the insurer’s case.
The Court further held that the filing of a charge-sheet under Section 304-A IPC prima facie supports the finding of negligence. The insurer’s failure to file any complaint with higher police authorities or seek investigation into alleged collusion rendered its allegations speculative. As held in Geeta Dubey, once the claimant establishes involvement on a balance of probabilities, the burden shifts to the insurer to disprove it - something it did not do.
The Verdict
The appellant-insurer’s appeal was dismissed. The Court held that the standard of preponderance of probability governs motor accident claims, and the insurer’s failure to rebut the claimants’ evidence or prove policy exclusion invalidated its defense. The award of ₹14,65,200 was upheld.
What This Means For Similar Cases
Preponderance of Probability Is the Sole Standard
- Practitioners must argue that MACTs are not criminal courts and should not apply criminal evidentiary standards.
- Insurers cannot defeat claims by pointing to minor inconsistencies in witness statements or delayed FIRs.
- Claimants need only show it is more likely than not that the vehicle caused the accident.
Insurer’s Burden to Disprove Collusion Is Strict
- If an insurer alleges collusion between claimants and driver, it must produce concrete evidence or initiate formal complaints.
- Silence or inaction by the insurer after learning of a claim constitutes waiver of the right to challenge the investigation’s integrity.
- Failure to examine available witnesses who could rebut the claimants’ version is fatal to the insurer’s case.
Documentary Evidence Does Not Automatically Trump Oral Testimony
- FIRs and insurance intimation are not conclusive; they are merely initial reports.
- Eyewitness testimony, even if delayed, is admissible if credible and unshaken in cross-examination.
- Tribunals must take a holistic view of all evidence, not isolate one document to dismiss the entire claim.
