Criminal acquittal does not negate independently established negligence in motor accident claims.

On 14 December 2017, Manoj was travelling in an Alto car allegedly driven by Bhagwan Singh when the vehicle met with an accident on the Mungaoli–Bahadurpur Road. Manoj died in the accident. An FIR was registered, and the police filed a charge-sheet against Bhagwan Singh and vehicle owner Vinod under Sections 337 and 304-A of the IPC

The Motor Accident Claims Tribunal awarded ₹10,85,000 to the claimants and, finding that Bhagwan Singh did not possess a valid and effective driving licence, exonerated the insurer while directing payment and recovery. The owner and driver challenged the award in M.A. No. 1845 of 2022, while the claimants sought enhancement in M.A. No. 5217 of 2022. Both appeals were decided by a common order dated 6 January 2026, which affirmed the finding of negligence and enhanced the compensation.

The owner and driver sought review, contending that the vehicle had been falsely implicated, that there was no eyewitness, and that they had subsequently been acquitted in the criminal case by judgment dated 21 November 2023.

Whether the review petitioners established that the vehicle had been falsely implicated and was not involved in the accident.

Whether the subsequent acquittal of the driver and owner in the criminal case warranted review or recall of the order passed in the motor accident appeals.

Whether the review petitions disclosed any permissible ground for interference with the order dated 6 January 2026.

Review jurisdiction cannot be used to reargue issues already considered and decided, particularly where the challenged findings are based on an appreciation of evidence.

In motor accident claims, the standard of proof is the civil standard applicable to negligence and is less stringent than the standard required to establish culpable rashness in a criminal prosecution.

In Mangla Ram v. Oriental Insurance Co. Ltd., (2018) 5 SCC 656, relying on N.K.V. Bros. (P) Ltd. v. M. Karumai Ammal, (1980) 3 SCC 457, the Supreme Court held that an acquittal in a criminal case does not by itself defeat a claim under the Motor Vehicles Act, since criminal culpability requires a higher standard of proof than civil negligence.

Accident claims tribunals must avoid allowing drivers and owners to escape liability merely because of doubts or technicalities and may infer negligence from the surrounding circumstances where reasonably justified.

The Court found that the defence of false implication was untenable because Bhagwan Singh himself stated in his examination-in-chief that Manoj, rather than he, was driving the car. Although this statement disputed the identity of the driver, it necessarily admitted the involvement of the vehicle in the accident.

The Court further held that the criminal acquittal could not justify review. The acquittal judgment had been delivered on 21 November 2023, well before the appellate order dated 6 January 2026, and the review petitioners had offered no explanation for failing to produce it before the Coordinate Bench.

In any event, applying Mangla Ram and N.K.V. Bros., the Court held that a criminal acquittal does not extinguish civil liability for negligence because the two proceedings operate under different standards of proof.

The findings of negligence had already been recorded by the Tribunal and affirmed by the High Court after considering the evidence, and no error apparent or other review ground was demonstrated.

Review Petition Nos. 583 and 678 of 2026 were consequently dismissed.