Criminal acquittal does not negate negligence established on a preponderance of probabilities in MACT proceedings.

On 20 April 2006, Praveen Sharma was riding a motorcycle near Rajiv Chowk, Gurgaon, with his brother, Raman Sharma, as pillion rider, when a truck owned by D.S. Construction Ltd. and driven by Darshan Singh allegedly collided with the motorcycle due to rash and negligent driving.

Sharma suffered severe pelvic, rectal, urinary and other bodily injuries and underwent extensive medical treatment and approximately 26 surgeries.

The truck was uninsured, and the Motor Accident Claims Tribunal (“MACT”) held the driver and owner jointly liable, awarding ₹37,19,000 with interest at 9% per annum.

The owner challenged the findings on negligence and quantum, while the claimant sought enhancement of compensation.

The driver was acquitted in the related criminal proceedings, but the acquittal was subsequently placed on record before the High Court.

Whether the claimant proved that the accident occurred due to the rash and negligent driving of the truck, notwithstanding the driver’s acquittal in the criminal proceedings?

Whether the MACT correctly assessed the claimant’s permanent and functional disability and loss of future earning capacity?

Whether the claimant was entitled to enhancement under medical expenses, attendant charges, pain and suffering, future prospects, and other heads of compensation?

What final compensation and consequential directions ought to be made in the cross-appeals?

The Court applied the civil standard of proof applicable in motor accident claims—preponderance of probabilities—rather than the criminal standard of proof beyond reasonable doubt.

It relied on Bimla Devi v. HRTC, (2009) 13 SCC 530; Anita Sharma v. New India Assurance Co. Ltd., (2021) 1 SCC 171; Mathew Alexander v. Mohd. Shafi, (2023) 13 SCC 510; ICICI Lombard General Insurance Co. Ltd. v. Rajani Sahoo, (2025) 2 SCC 599; Meera Bai v. ICICI Lombard General Insurance Co. Ltd., 2025 INSC 600; Ranjeet v. Abdul Kayam Neb, 2025 SCC OnLine SC 497; and Reena v. Managing Director, Karnataka State Road Transport Corporation, 2026 INSC 889, for the principle that an FIR, police investigation and charge-sheet constitute prima facie material regarding negligence, and that a criminal acquittal does not extinguish civil or tortious liability.

For computation of loss of future earnings, the Court applied the principles in National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, including future prospects and the appropriate multiplier.

The Court also applied the settled principle that functional disability may exceed or differ from physical disability depending on its impact on the claimant’s earning capacity and daily life.

The Court held that the driver’s criminal acquittal was not determinative because the criminal case required proof beyond reasonable doubt, whereas the MACT proceedings required only proof on a preponderance of probabilities.

The claimant’s brother, who was travelling as pillion rider, gave direct evidence of the truck approaching at high speed and colliding with the motorcycle; his testimony was corroborated by the prompt registration of the FIR, the charge-sheet, the claimant’s injuries and the undisputed involvement of the truck.

The owner led no evidence and did not examine the driver, and the alleged inconsistencies regarding the brother’s presence, hospital records and office timings were considered speculative and insufficient to displace the claimant’s evidence.

On quantum, the Court accepted the later AIIMS assessment of 49% permanent physical disability, together with the claimant’s extensive surgeries, pelvic and reproductive injuries, and inability to pursue employment, and assessed his functional disability at 80%.

It substituted the minimum wages of a graduate—₹4,031 per month—for the earlier matriculate minimum wages, added 40% future prospects, and applied a multiplier of 18.

It maintained the medical, conveyance and special-diet expenses, added ₹10,00,000 for attendant charges, and enhanced pain and suffering from ₹1,50,000 to ₹5,00,000.

It reassessed the claimant’s compensation at ₹53,16,000, rounded from ₹53,15,764, including ₹15,40,654 for medical treatment, ₹10,00,000 for attendant charges, ₹9,75,110 for loss of future income, ₹5,00,000 for pain and suffering, and ₹11,50,000 for loss of amenities and marriage prospects.

The enhancement was stated to be ₹15,97,000, with interest at 9% per annum from the date of filing of the claim petition.

The owner was directed to deposit the enhanced amount within four weeks; ₹10,00,000 was to be released to the claimant, and the balance was to be placed in staggered fixed deposits with interest credited to the claimant’s savings account.

The cross-appeals were disposed of accordingly, and pending applications were rendered infructuous.