Prolonged survival after an accident does not sever the proven causal nexus between injuries and death.

On 26 November 2013, Nanjibhai Bhojabhai Parmar was struck near Anandpar Crossing, National Highway No. 8-A, by Truck No. GJ-12-W-9649, allegedly driven rashly and negligently.

He sustained severe head injuries, including subdural and subarachnoid haemorrhage, and underwent surgery, ventilator support and tracheostomy.

He remained under treatment and died on 1 July 2014.

His wife, Jaluben, had initially instituted MACP No. 776 of 2014 seeking compensation for his injuries; during its pendency, the claim was converted into a death claim through a pursis dated 19 September 2022.

The Motor Accident Claims Tribunal awarded Rs. 5,06,177 with interest at 9% per annum from the date of filing until realization.

The insurer challenged the award under Section 173 of the Motor Vehicles Act, principally disputing the involvement of the truck and the causal nexus between the accident injuries and Nanjibhai’s subsequent death.

Whether the claimant proved, on the standard of preponderance of probabilities, that Truck No. GJ-12-W-9649 was involved in the accident and that its driver was rash and negligent?

Whether the claimant established a causal nexus between the injuries sustained in the accident and Nanjibhai’s death approximately eight months later, notwithstanding the absence of an autopsy?

The Court applied Section 173 of the Motor Vehicles Act, 1988 governing appeals against awards of the Motor Accident Claims Tribunal, and adjudicated the claim on the civil standard of preponderance of probabilities, rather than proof beyond reasonable doubt.

It relied on Mathew Alexander v. Mohd. Shafi & Anr., 2023 13 SCC 510, for the principle that criminal proceedings and MACT proceedings operate in distinct legal spheres and that criminal findings do not control civil motor accident adjudication.

It further relied on ICICI Lombard General Insurance Co. Ltd. v. Rajani Sahoo & Ors., 2025 2 SCC 599, and Geeta Dubey & Ors. v. United India Insurance Co. Ltd., 2024 SCC OnLine SC 3779, for treating police investigation papers, including the FIR and charge-sheet, as relevant prima facie material in MACT proceedings and for applying the preponderance-of-probabilities standard.

The Court also referred to Reena v. Managing Director, Karnataka State Road Transport Corporation, 2026 (0) AIJEL-SC 77486, concerning the evidentiary value of a charge-sheet in establishing a prima facie case of negligence.

The Court held that although the FIR was initially registered against an unknown vehicle and the spot panchnama did not show the truck, the eyewitness statement, police investigation papers and charge-sheet sufficiently established the truck’s involvement on a balance of probabilities.

The insurer did not effectively displace this evidence, and the relevant driver and owner were not examined, supporting the Tribunal’s findings on negligence.

On causation, the medical records showed that Nanjibhai had suffered extensive traumatic brain injuries, including a 12 mm subdural haematoma with mass effect and midline shift, subarachnoid haemorrhage, skull fracture, cerebral oedema and related complications.

He required craniotomy, ventilator support and tracheostomy.

The treating doctor testified that the accident-related injuries could have caused his death, and the insurer’s reliance on the notation that his condition was “stable” at discharge did not negate the medical evidence or establish an intervening cause.

The Court therefore found a sufficient causal nexus between the accident injuries and the eventual death, even without an autopsy.

It held that the involvement of Truck No. GJ-12-W-9649 and the causal connection between the accident injuries and Nanjibhai’s death were proved on a preponderance of probabilities.

The appeal was dismissed, and the Tribunal’s award of Rs. 5,06,177 with 9% annual interest was confirmed.

The amount deposited before the Tribunal was directed to be released to the claimant after verification of identity, and the record and proceedings were ordered to be returned.