Continuing-treatment evidence may be adduced on remand to assess just compensation.

Mohammed Asad appealed under Section 173(1) of the Motor Vehicles Act, 1988, seeking enhancement of the compensation awarded by the Tribunal in MVC No. 12/2021 for injuries sustained in a 2019 road accident. The Tribunal had awarded ₹18,45,224 with interest at 6% per annum.

During the appeal, Asad applied under Order XLI Rule 27 read with Section 151 of the Code of Civil Procedure to produce three medical bills and four photographs, stating that he had continued follow-up treatment and incurred further expenses. The insurer opposed the application, disputing the documents’ relevance and authenticity, including because the bills dated from 2025.

Under Order XLI Rule 27 read with Section 151 of the Code of Civil Procedure, an appellate court may permit additional evidence where the circumstances warrant it. An appeal is a continuation of the original proceedings, and the Motor Vehicles Act is beneficial legislation directed toward awarding just compensation to an injured person.

The court also applied the principle that the opposing party must have a fair opportunity to contest additional evidence and raise legally available objections.

The appellant asserted that the additional documents related to continuing treatment and expenses relevant to determining just compensation. The court considered that the documents’ authenticity, acceptability, and connection to the accident could not properly be determined at that stage; those matters could be tested through evidence and cross-examination before the Tribunal.

Given the beneficial purpose of the legislation and the continuation of the original proceedings on appeal, the court found it appropriate to allow the appellant to present the evidence. To protect the insurer’s interests, it expressly preserved the insurer’s right to object to the documents and raise all legally available contentions before the Tribunal.

It expressed no opinion on the merits, directed the parties to appear before the Tribunal on 5 November 2026 without awaiting fresh notice, and requested expeditious disposal.