FIR and charge-sheet sufficiently establish negligence in motor accident claims absent eyewitness testimony.

On 28 February 2015, Faizan and his cousin Hamid were standing near a motorcycle at Khandoli Chauraha, Agra, when tractor no. UP-80-BV-3730 allegedly struck them due to rash and negligent driving.

Faizan was declared brought dead, and a post-mortem was conducted; an FIR was subsequently registered and a charge-sheet was filed against the driver.

The Motor Accident Claims Tribunal initially dismissed the claim petition for want of proof of negligence.

On appeal, the High Court set aside that decision and remanded the matter for adjudication, holding that the delay in registration of the FIR was adequately explained by the victims’ immediate medical treatment and the family’s circumstances.

On remand, the Tribunal awarded compensation of ₹26,28,000 with interest at 9% per annum.

The Insurance Company challenged the award, principally disputing the involvement of the offending vehicle and the finding of negligence.

Whether the involvement and identity of tractor no. UP-80-BV-3730 in the accident were established despite alleged inconsistencies concerning its seizure, the vehicle’s chassis number, and the driver’s identity.

Whether negligence could be proved on the basis of the FIR, police investigation, and charge-sheet, notwithstanding the non-examination of an eyewitness and the Insurance Company’s challenge to the investigation.

Whether the Tribunal’s award of ₹26,28,000 with interest at 9% per annum warranted interference.

Claims before a Motor Accident Claims Tribunal are adjudicated on the touchstone of preponderance of probabilities, rather than the criminal standard of proof.

The Court relied on Ranjeet v. Abdul Kayam Neb, 2025 SCC OnLine SC 497, for the principle that once a charge-sheet has been filed holding the driver negligent, absence of further or eyewitness evidence is not necessarily fatal to proving negligence.

It further relied on Meera Bai v. ICICI Lombard General Insurance Company Ltd. & Anr., 2025:INSC:600, which held that an FIR and charge-sheet against the owner-driver may be sufficient to establish negligence even where the eyewitness is not examined.

The Court also applied its earlier order in MAC.APP. 143/2018, which held that a delay in FIR registration is not fatal where the circumstances reasonably explain the delay and a prompt DD entry and subsequent investigation establish continuity in the events.

The Court found that the Insurance Company’s objections did not displace the Tribunal’s finding.

Although the driver and owner stated that the tractor had been seized on the date of the accident, while the charge-sheet indicated that investigation commenced after registration of the FIR on 3 March 2015, this inconsistency was not considered fatal; the claimant’s explanation that the vehicle had already been secured and that the FIR merely initiated the formal investigation was plausible.

The vehicle’s presence in the vicinity, its seizure on the same day, the subsequent investigation, and the filing of the charge-sheet collectively supported its involvement on a balance of probabilities.

Applying Ranjeet and Meera Bai, the Court held that the FIR and charge-sheet constituted sufficient material to sustain the finding of negligence, even without eyewitness testimony.

The earlier finding that the FIR delay was satisfactorily explained also remained applicable.

The challenge to the Tribunal’s award was rejected, and the appeal was dismissed.

Pending applications were rendered infructuous, and any statutory deposit was directed to be refunded to the appellant-Insurance Company.