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The Supreme Court has overturned the Allahabad High Court's decision that denied compensation to the families of three teachers who lost their lives in a road accident in Uttar Pradesh more than two decades ago. Holding that the evidence had been wrongly appreciated by the courts below, the Court ruled that the accident occurred due to the rash and negligent driving of the tanker involved and directed the insurance company to pay compensation to the claimants.
Background of the Case
The case arose from a road accident that occurred on the night of January 30, 2002, on the Allahabad–Kanpur Road. A Maruti car carrying three school teachers and another occupant collided with a tanker. The three teachers died in the accident, while one passenger survived with serious injuries.
The legal representatives of the deceased filed claim petitions under Section 166 of the Motor Vehicles Act, 1988, seeking compensation. However, the Motor Accident Claims Tribunal (MACT) dismissed the petitions after accepting the defence's claim that the tanker was stationary and that the Maruti car had been driven negligently. The Allahabad High Court later affirmed that finding.
Supreme Court's Observations
A Bench of Justice Sanjay Karol and Justice Vipul M. Pancholi found significant flaws in the approach adopted by the Tribunal and the High Court.
The Court noted that the photographs relied upon by the lower courts were taken nearly ten hours after the accident by the tanker owner and could not be treated as reliable evidence of how the collision actually occurred.
The Bench observed:
“The photographs were not taken immediately after the accident... Such photographs cannot be treated as an accurate representation of the position of the vehicles at the time of impact.”
The Court instead placed reliance on the testimony of the sole surviving injured eyewitness, observing that an injured witness ordinarily carries greater evidentiary value unless there are strong reasons to reject such evidence.
The Bench further observed:
“The testimony of PW-2 is reliable and trustworthy.”
The Court also found that the respondents failed to produce the tanker conductor, who could have supported their version of events. It drew an adverse inference from this omission. Additionally, even if the tanker had been stationary, there was no evidence that it had been parked with proper warning lights or safety measures during the night.
According to the Bench, parking a heavy vehicle on a public road at night without adequate warning signals itself amounts to negligence.
Court Rejects Strict Criminal Standard
The Supreme Court reiterated that compensation proceedings under the Motor Vehicles Act are civil in nature and are decided on the preponderance of probabilities, not on the stricter criminal standard of proof beyond reasonable doubt.
The Bench said the Tribunal should have evaluated the evidence pragmatically, keeping in mind the beneficial object of the Motor Vehicles Act instead of adopting an overly rigid approach.
Decision
Allowing all three appeals, the Supreme Court held that the accident occurred due to the rash and negligent driving of the tanker bearing registration number UP-81E-6258. It set aside both the Allahabad High Court's judgment dated 28 August 2024 and the awards passed by the MACT.
The Court recalculated compensation for each set of claimants by applying the principles laid down in Sarla Verma and Pranay Sethi. It directed the respondent insurance company to deposit the awarded compensation within eight weeks.
The claimants were also held entitled to 6% annual interest from the date of filing of the claim petitions until realization, with any amount already paid under the no-fault liability provision to be adjusted against the final compensation.
