Motor accident claim tribunals must prioritize adjudication on merits over strict procedural technicalities when closing evidence.

The petitioners filed a claim case (No. 445/2020) before the Motor Accident Claims Tribunal, Gwalior, following the death of Kalla Jatav in a motor accident on January 16, 2020

During the evidence stage, after the claimants’ witnesses were examined, the petitioners filed an application under Section 169 of the Motor Vehicles Act on August 4, 2023, seeking permission to examine an independent witness present in court

The Tribunal rejected the application and permanently closed the petitioners' evidence on the same day

The petitioners challenged this order under Article 227 of the Constitution, arguing that as the deceased was the sole breadwinner, the closure of evidence after only five opportunities—compared to 9–10 granted to the respondent—would cause serious prejudice

1. Whether the Motor Accident Claims Tribunal acted with illegality or perversity in rejecting the application under Section 169 of the Motor Vehicles Act and permanently closing the claimants' evidence

2. Whether the denial of an opportunity to examine an independent witness in a summary proceeding under the Motor Vehicles Act constitutes a miscarriage of justice

The Court exercised its supervisory jurisdiction under Article 227 of the Constitution of India

It applied Section 169 of the Motor Vehicles Act, which mandates that the Claims Tribunal shall follow such summary procedure as it thinks fit

The court relied on the legal principle that proceedings under the Motor Vehicles Act are social welfare in nature and summary in character, requiring a liberal rather than a harsh or technical approach to ensure cases are decided on their merits

The Court observed that since the claim arose from the death of the sole earning member of a family in financial distress, the matter fundamentally deserved a decision on merits

It noted that the Tribunal’s approach was overly harsh, given that proceedings under the Motor Vehicles Act are intended to be summary

The Court reasoned that the recording of additional evidence by an independent witness would not prejudice the respondents, whereas its exclusion could lead to a miscarriage of justice by defeating a potentially valid claim

While acknowledging the need for timely disposal, the Court determined that procedural finality should not override the interests of justice in social welfare legislation

The Court granted the petitioners one final opportunity to lead their evidence, contingent upon the payment of a cost of Rs. 5,000 to be deposited before the Tribunal within two weeks

The Court clarified that no further opportunities would be granted beyond this single instance