Can Motor Accident Claims Be Rejected Solely on Delayed Photographs? Supreme Court Clarifies Standard of Proof
Case Name: Manju Singh v. Avinash Singh & Others
Date of Judgment: 13 July 2026
Citation: 2026 INSC 696 | Civil Appeal arising out of SLP (C) No. 10565 of 2025 (with SLP (C) Nos. 33538 & 33539 of 2025)
Bench: Justice Sanjay Karol and Justice Vipul M. Pancholi
Held: The Supreme Court held that Motor Accident Claims Tribunals must determine negligence on the preponderance of probabilities and not apply the stricter standard of proof required in criminal trials. The Court ruled that photographs taken several hours after an accident cannot, by themselves, conclusively determine negligence, particularly when contradicted by the testimony of an injured eyewitness.
Summary: The appeals arose from a motor vehicle accident in which three teachers lost their lives after a collision between a Maruti car and a tanker. The Motor Accident Claims Tribunal and the Allahabad High Court dismissed the claim petitions under Section 166 of the Motor Vehicles Act, holding that the accident occurred due to the negligence of the Maruti car driver, primarily relying on photographs taken nearly ten hours after the accident.
Before the Supreme Court, the claimants contended that the accident was caused by the rash and negligent driving of the tanker. The Court found that the photographs relied upon by the courts below were neither taken immediately after the accident nor by the investigating agency, making them unreliable. It instead placed reliance on the testimony of the sole surviving injured eyewitness, who consistently stated that the tanker collided with the Maruti car while it was being driven on the correct side of the road.
The Supreme Court further observed that the respondents failed to examine the tanker conductor, who was the best witness to support their defence, and failed to prove that the stationary tanker had adequate warning lights or safety precautions. Applying the principle of res ipsa loquitur, the Court held that the respondents had failed to discharge the burden of proving absence of negligence.
Decision: The Supreme Court allowed the appeals, set aside the judgments of the Allahabad High Court and the Motor Accident Claims Tribunal, and held the tanker driver negligent for the accident. It awarded compensation to the claimants in accordance with the principles laid down in Sarla Verma and Pranay Sethi, directing the insurance company to satisfy the award along with applicable interest.