Facts
The appellants, legal representatives of the deceased Sh. Dhirendra Singh (a police official), challenged the Motor Accident Claims Tribunal (MACT) judgment dated April 12, 2022, which dismissed their claim petition
Source reference: p.1, para 1On September 19, 2018, the deceased was riding his motorcycle near Kadirabad, UP, when he allegedly fell and sustained grievous injuries, later expiring on October 1, 2018
Source reference: p.1-2, para 2An FIR was lodged on the day of his death—12 days after the incident—against the driver of an alleged offending vehicle
Source reference: p.2, para 3The claimants relied on an eyewitness (PW-2) introduced seven months later via a supplementary charge sheet
Source reference: p.2, para 5However, the Medico-Legal Case (MLC) from Yashoda Hospital recorded that the deceased fell from his motorcycle due to potholes
Source reference: p.2, para 5; p.4, para 11The MACT dismissed the claim, citing these inconsistencies and the lack of primary medical records from the first hospital attended
Source reference: p.3, para 6Issues
1. Whether the claimants proved that the death was caused by the rash and negligent driving of the offending vehicle or if it was a self-fall due to road conditions.
Source reference: p.4, para 8; p.6, para 182. Whether the testimony of the eyewitness (PW-2) was credible given his delayed introduction and inconsistencies in his statement.
Source reference: p.4-5, paras 12-14Law Applied
The court applied the principles of negligence under the Motor Vehicles Act and sections 279/304A of the IPC
Source reference: p.2, para 3It emphasized the evidentiary value of a Medico-Legal Case (MLC) report, noting that recordings by independent medical professionals made at the first instance are "highly persuasive" as they are trained to record correct facts before litigation interests arise
Source reference: p.6, para 19The court also scrutinized the reliability of eyewitness testimony introduced after significant delay (seven months) without corroboration in contemporaneous documents
Source reference: p.5, para 14Reasoning
The Court affirmed the MACT's analysis, finding the claimants' version "incredulous"
Source reference: p.4, para 12First, it noted a critical evidentiary gap: the MLC from Jeevan Hospital (the first point of treatment) was never produced, despite the deceased being a local police official assisted by colleagues
Source reference: p.4, para 10Second, the subsequent MLC from Yashoda Hospital explicitly stated the head injury resulted from a bike fall caused by potholes at 3:45 AM
Source reference: p.4, para 11The Court found the eyewitness (PW-2) unreliable because he could not remember the motorcycle's details, was not mentioned in initial documents, and was only introduced seven months later
Source reference: p.5, para 13-14Furthermore, the Court observed that since the deceased was a police official in the same jurisdiction where the FIR was filed, the numerous procedural lapses and the 12-day delay in filing the FIR suggested the case might have been "created for purposes of compensation"
Source reference: p.5, para 15Holding
The Court held that the original MLC, which recorded the accident as a fall due to potholes, was dispositive of the nature of the event
It concluded that the claimants failed to prove the involvement of an offending vehicle or negligence by the respondents.
Source reference: p.6, para 20Consequently, the High Court found no reason to interfere with the MACT's well-reasoned judgment and dismissed the appeal
Source reference: p.6, para 20All pending applications were rendered infructuous
Source reference: p.6, para 21Original Court PDF
Sanju Chaudhary & Ors.vsJitender Kumar & Ors.
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