FIR and chargesheets constitute prima facie evidence of negligence in MACT proceedings.

On 28 September 2004, Rajeshbhai allegedly sustained serious injuries when motorcycle No. GJ-17-L-8770, driven by Respondent No. 1 in a rash and negligent manner, collided with his bicycle near Viraniya Highway.

He died during treatment on 2 October 2004.

His claimants, alleging that he was 18 years old, a student, and earning approximately ₹2,500 per month from miscellaneous work, filed a motor accident claim petition seeking ₹4,00,000 as compensation.

The Motor Accident Claims Tribunal, in MACP No. 996 of 2017, dismissed the claim petition on the ground that the motorcycle’s involvement in the accident was not established.

The claimants challenged that decision under Section 173 of the Motor Vehicles Act, 1988, relying principally on the FIR and chargesheet.

The respondents were served but did not appear before the High Court.

Whether the Tribunal erred in rejecting the claim petition by disbelieving the involvement of the offending motorcycle, despite the FIR and chargesheet forming part of the record.

Whether the matter required remand to enable proper assessment of the police investigation records and, if necessary, further evidence on the standard of preponderance of probabilities.

Whether the High Court could finally determine liability and compensation in the appeal, or whether the claim petition should be restored for fresh adjudication.

The appeal was filed under Section 173 of the Motor Vehicles Act, 1988, which permits an appeal against an award of the Claims Tribunal.

In ICICI Lombard General Insurance Co. Ltd. v. Rajani Sahoo & Ors., (2025) 2 SCC 599, the Supreme Court held that police investigation records, including the FIR and final chargesheet, constitute admissible and prima facie reliable evidence in motor accident proceedings, which are decided on civil standards and the preponderance of probabilities; criminal findings, including acquittal, do not control the MACT adjudication.

The High Court also relied on Reena v. Managing Director, Karnataka State Road Transport Corporation, 2026 INSC 889, which reiterated that a chargesheet creates a prima facie case of negligence, criminal acquittals do not displace prima facie civil liability, and MACT matters must be assessed according to the preponderance-of-probability standard.

The Tribunal must independently evaluate the entire evidence, including the investigating officer’s evidence where the vehicle’s involvement is disputed.

The High Court held that the Tribunal had not properly assessed the evidentiary value of the FIR and chargesheet under the civil standard applicable to MACT proceedings.

Instead, it focused on the vardhi and inquest panchnama contained in the chargesheet papers to reject the claimants’ case regarding the vehicle’s involvement.

In light of the principles in Rajani Sahoo and Reena, the FIR and chargesheet were capable of establishing a prima facie case and could not be discarded without a proper evaluation on the touchstone of preponderance of probabilities.

Since the investigating officer was considered material to resolving the factual controversy, and the claimants sought an opportunity to produce further evidence, the High Court found remand appropriate.

It expressly refrained from deciding the merits of the accident, negligence, or compensation claim.

The Tribunal’s judgment and award dated 18 August 2025 in MACP No. 996 of 2017 were quashed and set aside, and the claim petition was restored to the Tribunal’s file.

The parties were permitted to lead further evidence, if desired, and the Tribunal was directed to decide the matter afresh within six months, uninfluenced by the earlier judgment.

The High Court clarified that it had not adjudicated the merits of the claim.