FIR and charge-sheet filing against the driver establish negligence in summary motor accident claim proceedings.

The appellants filed claim applications before the Motor Accident Claims Tribunal (MACT), Baikunthpur, following a motor accident where they sustained injuries

The MACT, via an order dated 18.03.2019, rejected the claims on the grounds that the claimants failed to establish negligence on the part of the driver of the offending vehicle

The claimants, who were eyewitnesses to the accident, asserted that the driver (Respondent No. 1) dashed their motorcycle rashly and negligently, leading to an FIR and a subsequent charge-sheet under Sections 279, 337, and 338 of the Indian Penal Code (IPC)

1. Whether the Motor Accident Claims Tribunal erred in finding that negligence was not established despite the presence of eyewitness testimony and a criminal charge-sheet against the driver.

The Court applied the principles governing Section 166 of the Motor Vehicles Act, 1988, emphasizing that proceedings are summary in nature and do not require the strict standard of proof used in criminal trials

It relied on Meera Bai and others v. ICICI Lombard General Insurance Company Ltd. and another (2025 SCC OnLine SC 992), which held that if an FIR is lodged and a charge-sheet is filed against the driver, a finding of non-negligence is unsustainable

Furthermore, it applied Janabai Wd/o Dinkarrao Ghorpade and others v. ICICI Lombard Insurance Company Limited (2020) 10 SCC 512, establishing that the veracity of an injured claimant's statement should not be doubted based on the evidentiary requirements of a criminal trial

The Court observed that both claimants were eyewitnesses who provided consistent testimony regarding the rash and negligent conduct of the driver

The Court noted that the driver had been charge-sheeted under Sections 279, 337, and 338 of the IPC, which serves as prima facie evidence of negligence in summary claim proceedings

The Court reasoned that the Tribunal incorrectly applied a higher standard of proof, whereas the law settled by the Supreme Court dictates that the existence of a charge-sheet and eyewitness accounts are sufficient to establish negligence in motor accident claims

Since the Tribunal had already found that permanent disability existed but rejected the claim solely on the issue of negligence, the High Court determined the Tribunal's finding was legally unsustainable

The Court held that negligence on the part of the driver was clearly established through eyewitness testimony and the criminal prosecution records

The matter was remitted to the Motor Accident Claims Tribunal, Baikunthpur, with a direction to reassess and award compensation to the claimants within 45 days from the receipt of the judgment