Motor Accident Claims Under Section 166 MV Act: Supreme Court Upholds Dismissal Where Involvement of Offending Vehicle Not Proved on Preponderance of Probabilities

Case Name: Sithara N.S. & Ors. v. Sai Ram General Insurance Company Limited

Citation: 2025 INSC 1425

Date of Judgment/Order: 12 December 2025

Bench: Sanjay Karol, Prashant Kumar Mishra

Held: The Supreme Court dismissed the appeals and upheld the concurrent findings of the Motor Accident Claims Tribunal and the Karnataka High Court that the claimants failed to prove the involvement of the alleged offending vehicle—an essential requirement for maintaining a claim under Section 166 of the Motor Vehicles Act—even though the applicable standard of proof is preponderance of probabilities.

Summary: The legal representatives of two deceased persons filed claim petitions alleging that a canter lorry caused a fatal accident. Both the Tribunal and the High Court dismissed the claims on the ground that the involvement of the specific vehicle was not proved. Before the Supreme Court, the appellants argued that MACT proceedings require only preponderance of probabilities and not proof beyond reasonable doubt, and that reliance on FIRs, charge-sheets, and oral testimony was sufficient.

The Supreme Court reiterated that while the standard of proof in motor accident claims is indeed lower than in criminal trials, the claimant must nonetheless establish a credible link between the accident and the alleged offending vehicle. In the present case, the Court found serious infirmities in the evidence, including inconsistent witness testimony, a delayed and unreliable spot mahazar, and a Motor Vehicle Inspector’s report showing no damage to the alleged vehicle, which was incompatible with the severity of the accident. The Court held that these deficiencies justified the concurrent dismissal of the claims.

Decision: The appeals were dismissed with no order as to costs. The Supreme Court declined to interfere with the concurrent findings of fact, holding that the claimants failed to establish proof of involvement of the offending vehicle and consequent negligence as required under Section 166 of the Motor Vehicles Act.