Minor Record Mistakes Cannot Defeat a Genuine Injury Claim Under a Welfare Statute
Case Name: Raj Kumar Das (D) Through LRs. v. National Insurance Co. Ltd.
Citation: 2026 INSC 541
Date of Judgment/Order: 25 May 2026
Bench: Justice Vikram Nath and Justice Sandeep Mehta
Held: The Supreme Court held that motor accident compensation proceedings are summary and welfare-oriented in nature, and therefore claims must be decided on the standard of preponderance of probabilities, not proof beyond reasonable doubt. The Court clarified that in a claim under Section 163A of the Motor Vehicles Act, negligence need not be proved, and it is sufficient if the injury is reasonably connected with the motor vehicle accident. Minor discrepancies in medical history, FIR delay, vehicle number variation, hospital receipts or absence of independent eyewitnesses cannot defeat a genuine claim when the FIR, chargesheet, medical evidence and claimant’s testimony collectively establish the accident and resulting disability.
Summary: The original claimant, Raj Kumar Das, alleged that on 21.05.2004, after getting down from a rickshaw near Mondalpara Bus Stop, he was hit by a lorry bearing registration No. WB-41-3999, resulting in traumatic paraplegia and permanent disablement. He filed a claim under Section 163A of the Motor Vehicles Act seeking compensation, but the Motor Accident Claims Tribunal dismissed the claim on the ground that the accident itself was not proved, and the Calcutta High Court affirmed the dismissal. The Supreme Court found that the courts below had adopted a hyper-technical approach by treating discrepancies as fatal. The Court held that the isolated medical history entry mentioning “fall from lorry” could not override the claimant’s consistent testimony, FIR and chargesheet; delay in FIR was explainable because the claimant was undergoing treatment; a minor variation in vehicle number in oral evidence could not displace consistent documentary records; and non-examination of independent witnesses was not fatal where the claimant’s own testimony remained reliable. The Court emphasized that accident victims cannot be expected to produce perfect documentation while undergoing serious treatment, and welfare legislation must be applied with sensitivity to practical realities.
Decision: The Supreme Court allowed the appeal, set aside the judgments of the Motor Accident Claims Tribunal and the Calcutta High Court, and held the claimant’s legal representatives entitled to compensation. Considering the peculiar facts, the claimant’s 100% permanent disability, the long pendency since 2004, and the inadequacy of strict computation under the old Section 163A structured formula, the Court exercised powers under Article 142 and assessed compensation by drawing guidance from principles applicable under Section 166 claims. The Court awarded INR 14,90,000 with interest at 6% from the date of filing of the claim, directing the insurer to deposit the amount before the MACT within three months, whereafter it shall be released to the legal representatives of the original claimant in accordance with law. Pending applications were disposed of.