Unexplained delay in FIR and absence of MLC evidence justify rejection of motor accident claim.

The Appellant/claimant alleged that on April 27, 2018, he was hit by a motorcycle (MP-07-MN-4750) driven rashly by Respondent No. 1, resulting in a serious right knee injury requiring surgery

The FIR was lodged on May 4, 2018, seven days after the incident

The claimant filed a claim petition before the Motor Accident Claims Tribunal (MACT), Datia, which was dismissed on December 16, 2021

The claimant appealed the dismissal, arguing that the police investigation and subsequent charge-sheet established the vehicle's involvement

1. Whether the delay in lodging the FIR and the absence of a Medico-Legal Certificate (MLC) were fatal to the claimant's case for compensation

2. Whether the Claims Tribunal erred in disbelieving the evidence regarding the involvement of the offending vehicle

The court applied Section 166 of the Motor Vehicles Act regarding compensation claims and the principles governing the effect of delayed FIRs as established by the Supreme Court in Ravi v. Badrinarayan and Others (AIR 2011 SC 1226)

This precedent holds that while delay in lodging an FIR is not per se ground for dismissal, it necessitates "closer scrutiny" by the court to ensure the case is not fabricated or engineered to implicate innocent persons; the claimant must demonstrate "satisfactory and cogent reasons" for such delay

The Court observed that while the law permits condoning FIR delays if explained by the victim's trauma or medical priorities, the appellant in this case failed to provide any cogent explanation for the seven-day gap between the accident and the report

Crucially, the claimant failed to produce a Medico-Legal Certificate (MLC) dated the day of the accident (April 27, 2018) to medically corroborate that the injuries were sustained in a road traffic accident on that specific date

Consequently, the Court held that the Claims Tribunal correctly scrutinized the evidence and found the possibility of false implication of the vehicle for insurance purposes to be plausible

The Court found no perversity in the Tribunal's detailed findings across paragraphs 9 to 24 of the impugned award

The High Court affirmed the MACT’s decision, stating the findings were based on proper appreciation of evidence and settled legal principles

The Miscellaneous Appeal was dismissed