Criminal acquittal does not defeat motor accident liability established on a preponderance of probabilities.

On 17 November 2011, Ranjeetsinh Sabsinh died in a collision between his motorcycle and a jeep.

His widow and daughters filed a claim under Section 166 of the Motor Vehicles Act, 1988.

The Tribunal awarded them Rs.17,95,200 with 9% annual interest, finding the jeep driver 80% responsible and the deceased 20% responsible.

The insurer appealed, arguing that the jeep was not involved because the complainant and two spot-panchnama witnesses had turned hostile in the criminal trial and the jeep driver had been acquitted.

1. Whether the criminal acquittal and hostile witnesses established that the insured jeep was not involved in the accident, so as to displace the Tribunal’s finding in the claim proceedings.

2. Whether the Tribunal’s finding on involvement and liability could be sustained under the standard of proof applicable to motor accident claims.

Under Sections 166 and 173 of the Motor Vehicles Act, 1988, a claim tribunal determines entitlement to compensation and its decision may be challenged on appeal.

Motor accident claims are decided on the balance of probabilities, not proof beyond reasonable doubt; strict proof of the precise manner of the accident is not required.

The Court relied on Mathew Alexander v. Mohammed Shafi, (2023) 13 SCC 510, and New India Assurance Co. Ltd. v. Geetaben Nanlabhai Rathva, 2024 SCC OnLine SC 3779, on that standard; and on ICICI Lombard General Insurance Co. Ltd. v. Rajani Sahoo, (2025) 2 SCC 599, and Mangla Ram v. Oriental Insurance Co. Ltd., (2018) 5 SCC 656, concerning the evidentiary value of police records, including the FIR and charge-sheet, and the limited effect of a subsequent criminal acquittal in a motor accident claim.

The Tribunal had considered the complaint, accident-site panchnama, recovery panchnama and charge-sheet, and relied on the recorded damage to both the motorcycle and the jeep in finding that the jeep was involved.

The High Court held that the criminal acquittal—following the complainant’s and panch witnesses’ hostile testimony—did not determine the claim on the civil standard of proof and did not, by itself, negate the Tribunal’s finding.

Applying the preponderance-of-probabilities standard, the Court rejected the insurer’s non-involvement argument and found no basis to disturb the award.

It directed the Tribunal to disburse the compensation to the claimants if the amount was lying with it and ordered the record to be returned to the Tribunal.