MACTs Must Decide Accident Claims on Probabilities, Not Like Criminal Trials: SC

Motor Accident Claims Tribunal (MACT) proceedings are meant to provide speedy and just compensation to victims of road accidents.

Unlike criminal trials, they are not governed by the strict standard of proving negligence beyond reasonable doubt. Instead, tribunals are required to assess the evidence on the touchstone of preponderance of probabilities, keeping in mind the beneficial object of the Motor Vehicles Act.

Yet, in practice, many genuine claims are defeated because tribunals approach them as if they were criminal prosecutions.

The Supreme Court's decision in this case  is a timely reminder that MACT proceedings must remain victim-centric and cannot be decided on technical or speculative grounds.

What's The Matter?

Three families had been denied compensation for over twenty-four years after losing their sole breadwinners in a road accident.

The Tribunal concluded that the deceased car driver alone was negligent, relying primarily on photographs produced by the tanker owner.

The High Court affirmed that view, leaving the victims' families with only the statutory "no-fault" compensation.

The accident occurred in January 2002 when a Maruti car carrying three government school teachers collided with a tanker on the Allahabad-Kanpur Road. Three occupants died instantly, while Dr. Dileep Kumar Katiyar, the only surviving passenger, suffered grievous injuries.

The claimants consistently maintained that the tanker was being driven rashly and negligently. In contrast, the defence claimed that the tanker had been safely parked on the roadside while its conductor had stepped away, and that the Maruti car had rammed into it from the wrong side of the road.

The Supreme Court found serious flaws in the approach adopted by the courts below.

The Tribunal had treated photographs taken 10 to 12 hours after the accident and arranged by the tanker owner himself as decisive proof of negligence.

Justice Sanjay Karol observed that such photographs could never conclusively establish the position of the vehicles at the moment of impact, particularly when there was every possibility that the scene had changed before they were taken.

The Court held that mechanically relying on such evidence while ignoring more reliable material defeated the very purpose of the Motor Vehicles Act.

The judgment is equally important for the weight it accords to an injured eyewitness. Dr. Katiyar consistently deposed that the Maruti car was travelling on the correct side of the road and that the tanker struck it while coming from the opposite direction.

The Supreme Court held that an injured witness, whose presence at the scene is undisputed and who has himself suffered in the accident, ordinarily commands greater evidentiary value than interested witnesses attempting to defend their own conduct.

The Tribunal, according to the Court, committed a serious error by disregarding this testimony without any compelling reason.Another striking feature of the judgment is the Court's reliance on surrounding circumstances rather than isolated pieces of evidence.

The alleged conductor, whose absence formed the cornerstone of the defence, was never produced before the Tribunal.

There was also no evidence that the tanker had switched on hazard lights, parking lights, or reflective warning signs despite allegedly being parked on a public road at around 10 p.m.

The Court held that leaving a heavy vehicle on the roadway at night without adequate warning itself constitutes negligence and invoked the doctrine of res ipsa loquitur the thing speaks for itself—to shift the burden onto the respondents, who failed to discharge it.

Perhaps the most enduring contribution of the judgment lies in its reaffirmation of the evidentiary standard governing MACT proceedings. The Supreme Court reiterated that tribunals must evaluate claims on the basis of preponderance of probabilities, not the stricter standard applicable in criminal trials.

Motor accident compensation law is a piece of beneficial social welfare legislation intended to compensate victims rather than punish offenders.

A hyper-technical approach that ignores credible evidence in favour of doubtful material undermines that objective.

Setting aside the judgments of both the Tribunal and the High Court, the Supreme Court held the tanker driver negligent, awarded compensation in accordance with Sarla Verma and Pranay Sethi, and directed the insurer to satisfy the award.

For three families, the judgment brought long-delayed justice. For MACTs across the country, it serves as a reminder that the quest for compensation should not be defeated by rigid evidentiary formalism.

The decision reinforces a simple but vital principle: in welfare legislation, courts must look at the overall

probabilities of the case, not merely at isolated pieces of evidence that may create an illusion of certainty.