Tribunals should summon vehicle records under Order 16 Rule 6 CPC to ensure substantial justice in motor accident claims.

The petitioners filed a claim case (No. 867 of 2023) before the 12th Additional Motor Accident Claims Tribunal, Raipur, seeking compensation for the death of their relative in a motor accident.

The owner of the offending truck (Respondent No. 1) proceeded ex-parte, and the insurance company (Respondent No. 3) denied the existence of an insurance policy for the subject vehicle.

To verify ownership and insurance details, the petitioners moved an application under Order 16 Rule 6 of the Code of Civil Procedure (CPC) to summon registration documents from the Regional Transport Authority (RTO), Navrangpur, Odisha.

The Tribunal rejected the application on May 9, 2025, holding that the burden of proof lay on the claimants and that such applications could not be used to "collect evidence".

The petitioners challenged this rejection under Article 227 of the Constitution.

1. Whether the Tribunal’s rejection of the application under Order 16 Rule 6 of the CPC was justified given the ex-parte status of the owner and the insurer's denial of liability.

2. Whether the production of official registration documents from a transport authority constitutes an impermissible "collection of evidence" or a necessary step for the proper adjudication of a claim under beneficial legislation.

Order 16 Rule 6 of the CPC, which provides for the issuance of summons to any person to produce specific documents in their possession or power.

The principle that the Motor Vehicles Act is beneficial legislation intended to advance substantial justice to affected parties, necessitating a liberal approach toward procedural applications that facilitate the final adjudication of disputes.

The High Court observed that because the vehicle owner was ex-parte and the insurer denied liability, there was a high probability that any award in favor of the claimants would result in a "paper decree" that is unenforceable in the absence of verified registration or insurance details.

The Court reasoned that Order 16 Rule 6 of the CPC specifically exists to facilitate the production of documents necessary for deciding a dispute.

It found that summoning public records from the RTO would not cause prejudice to any party; rather, it would ensure a proper adjudication of the claim.

The Court rejected the Tribunal's view that this constituted "collecting evidence," characterizing it instead as a standard process for calling relevant evidence to resolve a controversy.

It held that the petitioners had made out a valid case for interference to ensure substantial justice.

The Tribunal was directed to issue summons to the RTO, Navrangpur, Odisha, strictly for the production of registration documents for vehicle No. OD-24-C-4953.

The Court clarified that the claimants are not entitled to examine the RTO as a witness of fact, and the order is restricted solely to the production of relevant documents.

Expenses for the proceeding are to be borne by the petitioners.