A charge-sheet prima facie establishes negligence in MACT proceedings, assessed on the preponderance of probabilities.

On 18 January 2010, Mukeshkumar was riding a motorcycle in Ahmedabad with a pillion rider when tanker No. GJ-1-X-7900 allegedly struck the motorcycle from behind. Mukeshkumar sustained multiple injuries and later died during treatment at L.G. Hospital, Ahmedabad.

His dependants filed claim petitions under Section 166 of the Motor Vehicles Act, claiming ₹13,00,000 in MACP No. 465 of 2010 and ₹7,50,000 in MACP No. 466 of 2010.

The Motor Accident Claims Tribunal awarded ₹9,61,000 in MACP No. 465 of 2010 and ₹2,60,000 in MACP No. 466 of 2010, with interest at 9% per annum from the date of the claim petitions until realization.

The insurer challenged the awards under Section 173 of the Motor Vehicles Act, contending that the tanker had been falsely implicated after the accident.

Whether the tanker was involved in the accident and was driven rashly or negligently, despite the tanker number and accused’s name not appearing in the initial FIR?

Whether the alleged inconsistencies between the FIR and the panchnama, and the insurer’s evidence, were sufficient to displace the Tribunal’s finding of liability?

Whether the Tribunal’s awards of ₹9,61,000 and ₹2,60,000, with 9% interest, warranted appellate interference under Section 173 of the Motor Vehicles Act?

Claims under Section 166 of the Motor Vehicles Act are adjudicated on the standard of preponderance of probabilities, and not proof beyond reasonable doubt.

Under Section 173, an appellate court must carefully assess the oral and documentary evidence before reversing a reasoned MACT award.

The Court relied on Geeta Dubey v. United Insurance Co. Ltd., [2024 SCC OnLine SC 3779], for these principles.

It further relied on ICICI Lombard General Insurance Co. v. Rajani Sahoo, (2025) 2 SCC 599, and the principles drawn from Mangla Ram v. Oriental Insurance Co. Ltd., Mathew Alexander v. Mohammed Shafi, and Dulcina Fernandes v. Joaquim Xavier Cruz, that FIRs, charge-sheets, and police investigation records may constitute relevant prima facie evidence of negligence in motor accident claims, and that a criminal acquittal does not determine civil liability under the Motor Vehicles Act.

The Court also referred to Reena v. Managing Director, Karnataka State Road Transport Corporation, 2026 (0) INSC 889, reiterating that a charge-sheet may establish a prima facie case of negligence and that a High Court should not summarily overturn a MACT award without applying the preponderance-of-probabilities standard.

The insurer’s failure to produce its officer’s affidavit under Order XVIII Rule 4 of the Code of Civil Procedure was also considered relevant.

The Court held that the later incorporation of the tanker’s details and the driver’s name in the FIR did not, by itself, render the claim doubtful.

The police had subsequently filed a charge-sheet against the tanker’s driver, and those criminal proceedings had not been challenged by him before any competent forum.

The driver-cum-owner’s testimony was also unpersuasive: although he denied that his tanker caused the accident, he admitted that he had been arrested in connection with the accident and that a charge-sheet had been filed against him.

Applying the civil standard of preponderance of probabilities, the Court treated the police records and charge-sheet as supporting the tanker’s involvement.

It found that the alleged discrepancy between the FIR’s reference to a rear impact and the panchnama’s description of damage to the motorcycle’s front portion was insufficient to outweigh the overall evidence.

The insurer also failed to lead satisfactory affirmative evidence through its own officer, while the driver’s evidence did not rebut the prosecution and documentary material.

Accordingly, the Tribunal’s finding fastening liability on the vehicle’s owner and insurer was not shown to be perverse or legally erroneous.

Both appeals were dismissed, and the Tribunal’s awards of ₹9,61,000 and ₹2,60,000, together with 9% annual interest, were upheld.

The Tribunal was directed to disburse the awarded amounts, with accrued interest, to the claimants after due verification, subject to deduction of court fees if payable.

The record and proceedings were ordered to be returned to the Tribunal.