Motor accident claims fail where the claimant cannot reliably establish the offending vehicle’s involvement.

The appellants challenged the award dated 28 October 2006 passed by the Motor Accidents Claims Tribunal, District Seoni, in Claim Case No. 22/2004, whereby their claim was dismissed.

They alleged that the deceased was involved in an accident caused by Truck No. MP-20-H-5033, owned by respondent Nos. 1 and 2, and sought compensation under Section 173 of the Motor Vehicles Act.

The FIR lodged on the date of the incident, 11 March 2004, initially referred to an unknown vehicle; the vehicle’s registration number was disclosed approximately 20 days later.

The Tribunal found material inconsistencies in the evidence of Mahendra Singh and Rajesh Kumar Verma (PW-3), the principal witness relied upon by the claimants.

In contrast, the respondents’ witnesses stated that the vehicle was under repair and not in running condition on the relevant date, which was also consistent with the police investigation.

The Tribunal consequently held that the vehicle had been falsely implicated and dismissed the claim.

Whether the appellants established that Truck No. MP-20-H-5033 was involved in the accident in which the deceased sustained fatal injuries?

Whether the Tribunal erred in disbelieving the claimants’ evidence and relying upon the respondents’ evidence regarding the vehicle’s condition and whereabouts?

Whether the principle stated in Koncham Lavanya v. Bajaj Allianz General Insurance Co. Ltd. , 2025 INSC 452, required the claim to be accepted in the present case?

Whether the Tribunal’s findings disclosed perversity or illegality warranting interference in appeal under Section 173 of the Motor Vehicles Act?

The Court applied Section 173 of the Motor Vehicles Act, under which an aggrieved party may appeal against an award of the Motor Accidents Claims Tribunal.

The claimant must establish, on the evidence available in the claim proceedings, that the alleged offending vehicle was involved in the accident.

Although strict rules of evidence are not applied with the same rigidity in motor accident claims, the foundational fact of involvement of the vehicle must still be supported by credible and reliable evidence.

Appellate interference is warranted where the Tribunal’s findings are illegal or perverse; concurrent factual findings based on proper appreciation of evidence do not ordinarily call for interference.

The Court considered Koncham Lavanya v. Bajaj Allianz General Insurance Co. Ltd. , 2025 INSC 452, but held that its principle could not be mechanically applied where the respondents had led specific evidence and the police investigation did not support the alleged involvement of the vehicle.

The Court held that the delayed disclosure of the vehicle’s registration number, after an FIR against an unknown vehicle, created a material doubt regarding the truck’s involvement.

Mahendra Singh’s evidence was inconsistent as to when he learned the vehicle number, while PW-3, Rajesh Kumar Verma, was treated as an interested witness whose testimony contained contradictions regarding the vehicle, driver, and manner in which the injured person was taken to hospital.

His evidence also conflicted with PW-1’s account that the deceased’s body was lying on the road with a cycle.

Conversely, DW-1 to DW-4 consistently supported the respondents’ case that the truck was under repair and not operational on the date of the accident, and the police investigation did not establish its involvement.

Since no independent and reliable evidence connected Truck No. MP-20-H-5033 with the accident, the Court found no perversity or illegality in the Tribunal’s assessment.

Koncham Lavanya was distinguished because, unlike that case, the respondents here had produced a specific defence supported by evidence.

The Tribunal’s dismissal of the claim was based on proper appreciation of the evidence and disclosed no perversity or illegality warranting appellate interference.

Accordingly, the appeal was dismissed, with no order as to costs.