Rear-end collision liability rests on the following vehicle for failing to maintain safe distance despite sudden braking.

On May 16, 2014, the deceased (Ish Narayan) was driving a Maruti Van/Ambulance with PW-2 (Vijay Kumar) as a passenger.

A truck driven by Respondent No. 1 overtook the van and allegedly applied sudden brakes, causing the van to strike the truck from behind; the deceased sustained fatal injuries.

The Appellants (parents) filed a claim under Sections 166 and 140 of the Motor Vehicles Act, 1988.

The Motor Accidents Claims Tribunal (MACT) dismissed the petition on April 2, 2018, holding that the claimants failed to prove negligence on the part of the truck driver, noting that the vehicle following from behind must maintain a safe distance.

The claimants appealed, citing the FIR, charge-sheet, and testimony of PW-2 regarding the truck’s sudden braking.

Whether the accident occurred due to the rash and negligent driving of Respondent No. 1 (truck driver) to establish liability under Section 166 of the MV Act.

Whether the Appellants are entitled to compensation under the principle of "no-fault liability" under Section 140 of the MV Act despite the failure to prove negligence.

The court primarily applied Section 166 of the Motor Vehicles Act, 1988, which requires the claimant to prove "fault" or negligence.

It relied on Regulation 23 of the Rules of the Road Regulations, 1989, which mandates that a driver must keep a sufficient distance from the vehicle in front to avoid collision during sudden deceleration.

The court followed the precedents of Nishan Singh v. Oriental Insurance Co. Ltd. (2018) and Prasanna v. Kerala State Road Transport Corp (2009), which establish that sudden braking is often a reflex action and the primary responsibility to avoid a rear-end collision rests with the following vehicle.

Finally, it applied Section 140 of the MV Act regarding "no-fault liability" as interpreted in Indra Devi v. Bagada Ram.

The Court observed that under Section 166, the burden of proof lies on the appellants to establish negligence on a preponderance of probabilities.

The court found that the Maruti Van struck the truck from behind, and as per Regulation 23, the van driver failed to maintain a "sufficient distance".

The Court noted that PW-2’s testimony was inconsistent, as he was sitting in the rear and admitted in criminal proceedings (which ended in the driver's acquittal) that the accident occurred at night with low visibility.

The mere allegation of sudden braking without corroborating evidence of speed or road width was insufficient to displace the presumption of negligence by the rear vehicle.

Consequently, the Court found no evidence of rashness by the truck driver but held that the beneficial nature of the Act allowed for relief under "no-fault" provisions.

However, the Court partially allowed the appeal by granting limited relief under Section 140 of the MV Act.

The Respondents (owner/insurer) were held jointly and severally liable to pay Rs. 50,000/- to the Appellants on the principle of no-fault liability, along with 9% interest per annum from the date of the claim petition until realization.