Supreme Court rules that FIR alone cannot establish a motor accident. Eyewitness testimonies and credible evidence are crucial for proving claims and securing rightful compensation.
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NEW DELHI: In a landmark decision, the Supreme Court of India emphasized the importance of credible evidence in motor accident claims, particularly when relying on First Information Reports (FIRs) and eyewitness testimonies. The bench of Justices K Vinod Chandran and N V Anjaria clarified that while FIRs can be relied upon to establish the rash and negligent driving of a vehicle, the probative value of an FIR diminishes when its authenticity or registration process is questionable.
Case Background
The case involved claimants Rajamma and others, who sought compensation for the death of their husband and father in a hit-and-run road accident at Singasandra Crossroad on June 18, 2014. According to the claimants, the accident was witnessed by a neighbor, and the driver of the offending vehicle allegedly abandoned the victim’s body instead of taking him to a hospital.
The Motor Accident Claims Tribunal (MACT) initially awarded Rs 16,02,000 to the claimants, dismissing the insurance company’s allegations of fraud and questioning the involvement of the vehicle.
However, the High Court reversed the MACT order, stating that neither the accident nor the involvement of the vehicle was conclusively proven. The case eventually reached the Supreme Court for review.
Findings of the Supreme Court
The Supreme Court noted discrepancies regarding the FIR, which was lodged at Hebbogodi Police Station, outside the jurisdiction where the accident occurred. The FIR was transferred to the Electronic City Traffic Police Station only after 117 days.
“If the FIR is registered on the basis of the accident or on the detection of the abandoned body, then it should have been registered in a Police Station having jurisdiction over either of the two locations,”
the bench observed.
No police personnel were examined to justify the delayed and improper registration, raising doubts about the FIR’s credibility.
The court also questioned the testimony of the alleged eyewitness, who claimed to have witnessed the accident while running a roadside fruit shop.
- No proof, such as a valid license, was provided to establish that the witness operated the shop.
- The witness claimed to have noted the vehicle number along with the victim’s daughter, yet also stated that the victim and vehicle had disappeared when she returned with the daughter—a contradiction noted by the bench.
- The victim’s daughter was never examined in court to corroborate the account.
Due to these inconsistencies, the court categorized the eyewitness as a chance witness and emphasized the need for strict scrutiny.
The Supreme Court upheld the High Court’s decision, rejecting the claimants’ compensation claim. It highlighted that the driver had already been acquitted in the criminal case, and there was no compelling evidence to link the vehicle to the alleged accident.
The judgment reinforces that in motor accident claims, proof must be based on the preponderance of probabilities. FIRs and eyewitness accounts are relevant but can be disregarded if:
- The FIR’s registration is improper or delayed
- The eyewitness testimony is inconsistent or uncorroborated
- Other evidence raises suspicion regarding the claim
Case Title:
Rajamma & Ors Vs M/s Reliance General Insurance Co Ltd & Anr
Civil Appeal No.5172 of 2025
Read Judgment: