Mere exhibition of documents does not dispense with the requirement of proving them according to law.

On 17.09.2014, the deceased, Tirath Kumar Savita, allegedly sustained fatal injuries after being struck by a Vikram Loading vehicle (MP-07-L-2532) driven by Respondent No. 1

He succumbed to his injuries on 22.09.2014

A police report (Merg) was registered on the date of death, but the FIR was lodged only on 04.10.2014

The Appellants filed a claim petition under Section 163-A of the Motor Vehicles Act, 1988, which was rejected by the 17th Motor Accident Claims Tribunal, Gwalior, on 18.05.2018

The Tribunal found that the claimants failed to prove the involvement of the offending vehicle and the cause of injury

1. Whether a delay in lodging an FIR is inherently fatal to a motor accident claim petition

2. Whether the Appellants successfully proved that the deceased sustained injuries in a road traffic accident involving the offending vehicle

The court applied Section 173(1) of the Motor Vehicles Act, 1988, regarding appeals against awards.

It relied on the precedent set in Ravi v. Badrinarayan and Others (AIR 2011 SC 1226), which establishes that while FIR delay is not per se fatal to a claim, it requires the court to scrutinize evidence more closely to rule out fabrication.

Furthermore, the court applied the Indian Evidence Act principle that the mere exhibition of a document (marking it as an exhibit) does not dispense with the legal requirement of proving the document through competent testimony or evidence.

The Court observed that while delay in an FIR can be condoned if satisfactory reasons exist

the Appellants failed to provide medical corroboration of a road accident on the alleged date of occurrence (17.09.2014).

Although hospital records (Exhibit P-12) confirmed admission, they failed to mention that the injuries were result of a motor vehicle accident, leading to an adverse inference.

Regarding Exhibit P-10 (an application to the SP), the Court held it was not "duly proved" because the Appellants failed to examine the police officer who allegedly received it.

Since the Appellants could not bridge the evidentiary gap between the injury and the specific involvement of the offending vehicle, the Court found no error in the Tribunal's meticulous dismissal of the claim.

The Court held that the Tribunal properly appreciated the evidence and that the Appellants failed to prove their case.

Consequently, the appeal was dismissed, and the impugned award dated 18.05.2018 was upheld.