Mere Filing of Chargesheet Does Not Prove Negligence in Motor Accident Claim When Offending Vehicle’s Involvement Is Doubtful; Beneficial Nature of Motor Vehicles Act Cannot Justify Compensation on a False Claim: Punjab & Haryana High Court
Case Name: Rajni Devi and Another v. Kulbir Singh and Others; Rajo Devi and Another v. Kulbir Singh and Others
Date of Judgment: 4 August 2026
Citation: FAO-2590-2003 & FAO-2591-2003
Bench: Hon’ble Mr. Justice Yashvir Singh Rathor
Held: The Punjab and Haryana High Court held that mere filing of a chargesheet or framing of charge against a driver is insufficient to establish involvement of the alleged offending vehicle or rash and negligent driving for awarding compensation under Section 166 of the Motor Vehicles Act, 1988. The claimants must establish their case through cogent and convincing evidence, even though the applicable standard is preponderance of probabilities.
Summary: The appeals arose from the death of Raghbir Singh and Randhir Singh in a motor accident on 13 December 1999. The MACT dismissed their families’ compensation claims after finding that the alleged Fiat car had been falsely introduced as the offending vehicle.
The High Court examined the testimony of the alleged eyewitness, who claimed that he saw the Fiat car hit the motorcycle and even chased it. However, he neither assisted the victims nor immediately informed the police and surfaced only later. The original FIR itself had been registered against an unknown vehicle. The Court found these circumstances sufficient to doubt whether he had actually witnessed the accident.
The Court observed that although the Motor Vehicles Act is beneficial legislation and the standard of proof is comparatively liberal, public money cannot be awarded on false claims. Even applying the test of preponderance of probabilities, the claimants failed to establish that the alleged car was involved in the accident or that its driver was negligent.
Decision: Both appeals were dismissed, and the MACT’s finding that the accident was a hit-and-run involving an unknown vehicle and that the alleged offending car had not been proved to be involved was affirmed.