A claims tribunal need initiate forgery proceedings only when it considers them expedient in the interests of justice.

The insurer challenged an order dated 25 August 2026 of the 2nd Motor Accident Claims Tribunal (SD), Berhampur, in MAC No. 102 of 2025.

Before the Tribunal, the insurer sought to summon the Income Tax Officer to establish alleged fraud concerning a document marked Ext.17 and requested an inquiry under Section 169(2) of the Motor Vehicles Act, 1988, read with Section 379 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS).

The claimants sought recall of Ext.17 and an award based on other income-tax and bank documents.

The insurer also asserted that it had not received sufficient opportunity to lead evidence.

1. Whether the Tribunal could initiate an inquiry under Section 169(2) of the Motor Vehicles Act read with Section 379 of the BNSS concerning the alleged use of a false document.

2. Whether summoning the Income Tax Officer to verify Ext.17 was necessary in the circumstances.

3. Whether the insurer should be granted further time to complete its evidence.

Section 169(2) of the Motor Vehicles Act confers specified civil-court powers on a Claims Tribunal, including powers relating to evidence, witness attendance and production of documents, and deems the Tribunal a civil court for the purposes stated in that provision.

Section 379 of the BNSS provides a mechanism for a court to make a written complaint concerning specified offences connected with proceedings or documents produced in evidence, where the court considers an inquiry expedient in the interests of justice.

The decision to invoke that mechanism is discretionary, not automatic; under Iqbal Singh Marwah v. Meenakshi Marwah, the court assesses expediency by considering the effect of the alleged offence on the administration of justice, rather than simply the injury to the affected person.

The Tribunal may also use its inherent power under Section 151 of the Code of Civil Procedure to recall or expunge an exhibit where no express CPC provision addresses that step.

The Court observed that the claimants had not pressed Ext.17 and that, on the parties’ submissions, it was not a genuine document.

The Tribunal could therefore disregard or recall it, making it unnecessary to summon the Income Tax Officer to establish its veracity.

As to an inquiry or complaint, Section 379 did not require action in every case: the relevant question was whether it was expedient in the interests of justice, assessed in light of the effect on the administration of justice.

The Court also considered that claimants in compensation proceedings may not understand the purport of documents produced on their behalf.

Separately, to ensure fairness, it considered further time for the insurer to complete its evidence just and proper.

The Court directed the Tribunal to allow the insurer 30 days from production of the High Court’s order to complete its evidence.

The claimants were directed to cooperate, and the Tribunal was requested to dispose of the claim expeditiously.

There was no order as to costs.