Reaffirming the Evidentiary Burden to Prove Vehicle Involvement in Motor Accident Claims and Limits on Supreme Court Interference with Concurrent Findings: A Commentary on Sithara N.S. v. Sai Ram General Insurance Co. Ltd., 2025 INSC 1425

I. Introduction

The decision of the Supreme Court of India in Sithara N.S. & Ors. v. Sai Ram General Insurance Company Limited, 2025 INSC 1425, delivered on 12 December 2025 by a Bench comprising Sanjay Karol, J. and Prashant Kumar Mishra, J., deals with a recurring and sensitive issue in motor accident claims: what level and quality of evidence is required to prove the involvement of a particular vehicle and its driver in a fatal accident under Section 166 of the Motor Vehicles Act, 1988?

The case arises out of a tragic road accident in which two young men, Sunil Singh (26) and Shivu (22), lost their lives while travelling on a motorcycle. Their legal representatives filed claim petitions for compensation before the Motor Accident Claims Tribunal (MACT), Shimoga, alleging that a canter lorry driven rashly and negligently had caused the accident. Both the MACT and the High Court of Karnataka rejected the claims, holding that the claimants had failed to prove the involvement of the alleged offending vehicle. The Supreme Court was approached through Special Leave Petitions converted to Civil Appeals Nos. 14718–14719 of 2025.

The decision is important because it:

• Reiterates that in motor accident claims, the standard of proof is “preponderance of probabilities”, not “proof beyond reasonable doubt”, yet simultaneously insists that core foundational facts — especially the involvement of a specific vehicle — must be established through cogent and credible evidence.
• Affirms the limited scope of Supreme Court interference under Article 136 of the Constitution with concurrent findings of fact by the MACT and the High Court.
• Clarifies the evidentiary value (and limitations) of documents such as FIRs, charge-sheets, spot mahazars, inquest reports and Motor Vehicle Inspector’s (MVI) reports in MACT proceedings.

While the judgment does not radically transform the law, it meaningfully consolidates and applies existing principles to emphasize an evidentiary threshold: even in a beneficial legislation like the Motor Vehicles Act, courts cannot award compensation merely on sympathy or conjecture when vehicle involvement itself is not satisfactorily proved.

II. Factual Background and Procedural History

1. The Accident

On 14 August 2013, at about 11:30 p.m., Sunil Singh and his friend Shivu were returning from Honnali on a motorcycle (Registration No. KA-14-ED-9828). Near Sugur village, it was alleged that a canter lorry (Registration No. KA-20-AA-6786), driven rashly and negligently by respondent no. 1 (driver), dashed against the motorcycle:

• Shivu died on the spot.
• Sunil Singh succumbed to his injuries later in hospital.

The legal representatives (LRs) of both deceased persons filed separate claim petitions under Section 166 of the Motor Vehicles Act:

• MVC No. 1155/2013 – by LRs of Sunil Singh.
• MVC No. 1156/2013 – by LRs of Shivu.

The canter lorry was stated to be insured with Sai Ram General Insurance Co. Ltd. (respondent no. 3).

2. Findings of the MACT (Tribunal)

The MACT, Shimoga (Motor Accident Claims Tribunal-VII), after recording evidence, dismissed both petitions on 30 April 2015. Its key findings, as later noted and endorsed by the Supreme Court, were:

• There were serious inconsistencies and contradictions in the evidence of the claimants’ witnesses.
• The alleged eye-witnesses (P.W.3 and P.W.4) materially contradicted themselves and their version that the driver had “confessed” to them was considered inherently improbable and contrary to normal human conduct.
• Foundational facts such as the identification and involvement of the specific lorry in the accident were not satisfactorily established.

3. High Court Proceedings

Aggrieved, the LRs filed appeals before the High Court of Karnataka, Bengaluru, being MFA Nos. 5891/2015 and 5892/2015 (MV). By a common judgment dated 7 June 2018, the High Court:

• Dismissed the appeals; and
• Affirmed the Tribunal’s conclusion that the involvement of the alleged offending vehicle had not been proved.

The High Court endorsed the Tribunal’s appreciation of evidence and held that the claimants had failed to satisfy the evidentiary requirements under Section 166 of the Motor Vehicles Act.

4. Supreme Court Appeals

The legal representatives approached the Supreme Court via SLP (C) Nos. 281–282/2019, later converted to Civil Appeal Nos. 14718–14719 of 2025. Notably, as recorded in a footnote, the SLPs:

• Were closed against the driver (respondent no. 1) and owner (respondent no. 2) of the vehicle on 2 November 2023 for non-prosecution, and they were deleted from the array of parties.
• Thus, only the insurer (respondent no. 3, Sai Ram General Insurance Co. Ltd.) remained as the contesting respondent.

The central question before the Supreme Court was: Did the High Court err in law in upholding the finding that involvement of the alleged offending lorry was not proved, warranting interference with the concurrent findings?

III. Summary of the Judgment

The Supreme Court dismissed the appeals, maintaining the concurrent findings of the Tribunal and the High Court that the claimants had failed to prove the involvement of the canter lorry (KA-20-AA-6786) in the accident.

Key elements of the decision:

• The Court emphasized the extraordinary and limited nature of jurisdiction under Article 136 of the Constitution. Interference with concurrent findings of fact is permissible only when the findings are perverse or based on wholly unsatisfactory appreciation of evidence.
• After reviewing the evidence, the Court held that the Tribunal’s findings regarding:
  • Inconsistencies in witness testimonies,
  • The improbability of the alleged confessional statements by the driver,
  • The absence of any damage to the alleged offending vehicle per the MVI report,
  were reasonable and not perverse.
• The Court acknowledged that:
  • In motor accident claims, the standard of proof is preponderance of probabilities;
  • FIRs are not encyclopedias, and the omission of a registration number in an FIR is not by itself fatal;
  • Nonetheless, the overall evidence must establish a credible connection between the accident and the alleged offending vehicle.
• In this case, multiple infirmities—including the delayed and non-specific complaint, questionable testimonies of supposed eyewitnesses, and a Motor Vehicle Inspector’s report showing no damage to the alleged lorry—undermined the case.
• The Court expressed sympathy for the loss of two young lives but underscored that compensation cannot be awarded on sympathy alone without a legally sustainable finding of liability.

Consequently, the appeals were dismissed, with no order as to costs.

IV. Detailed Legal Analysis

A. Precedent on Interference with Concurrent Findings: Collector Singh v. L.M.L. Limited, Kanpur

The only reported precedent explicitly cited is Collector Singh v. L.M.L. Limited, Kanpur, (2015) 2 SCC 410. In that case, the Supreme Court clarified the nature of its jurisdiction under Article 136 of the Constitution, particularly when concurrent findings of fact are under challenge.

The Court in Collector Singh observed (as quoted in para 12 of the present judgment) that:

“Jurisdiction under Article 136 of the Constitution of India is extraordinary and interference with the concurrent findings of fact recorded by the courts below is permissible only in exceptional cases and not as a matter of course.”

The Court further held that such interference is justified only where:

• The appreciation of evidence is wholly unsatisfactory, or
• The conclusions are perverse, i.e., contrary to the evidence or such that no reasonable person could have reached them.

In Sithara N.S., this precedent is crucial in two respects:

1. It frames the scope of what the Supreme Court can (and cannot) do in an appeal under Article 136 against MACT/High Court findings. The Court reiterates that it is not a regular fact-finding court and will not reweigh evidence unless there is clear perversity.
2. It provides the standard against which the Court evaluates the MACT’s and High Court’s assessment of evidence. Once the Court concludes that their appreciation was reasonable, it declines to interfere.

Thus, rather than revisiting the entire factual matrix de novo, the Court’s inquiry is confined to whether the lower fora’s approach to evidence was so flawed that intervention becomes necessary. The judgment firmly answers this in the negative.

B. Legal Issues and the Court’s Reasoning

1. Core Legal Issue

The central issue may be formulated as:

Whether the claimants had, on a preponderance of probabilities, established the involvement of canter lorry KA-20-AA-6786, driven by respondent no. 1, in the accident that caused the death of Sunil Singh and Shivu; and, if not, whether the Supreme Court should disturb the concurrent findings of the MACT and High Court under Article 136 of the Constitution.

2. Standard of Proof under Section 166 of the Motor Vehicles Act

The insurer’s counsel argued (para 7–8) that, to succeed under Section 166 MV Act, a claimant must prove:

1. The occurrence of an accident;
2. The involvement of a particular vehicle;
3. Rash and negligent act on the part of the vehicle’s driver.

The Court accepts in principle that:

• These elements constitute the foundational facts for establishing liability in a fault-based claim under Section 166.
• The standard of proof is “preponderance of probabilities”, consistent with civil proceedings, as reiterated in para 16: the Court is “conscious of the settled legal position” on this point.

However, the Court draws a crucial distinction:

• While the standard is lower than “beyond reasonable doubt”, it is not so lax as to allow findings based purely on suspicion, conjecture, or sympathy.
• The identity and involvement of the alleged offending vehicle must be supported by “cogent and reliable evidence” (para 16).

3. Evaluation of Oral Evidence

(a) Testimony of P.W.1 (Parashuram Singh) and P.W.2 (Parmesh)

P.W.1 and P.W.2, being close family members and appellants in the respective appeals, were considered “star witnesses” for the claimants.

The Tribunal (and the Supreme Court, at paras 13–14) noted the following issues:

• P.W.1 gave self-contradictory statements: stating at one point that he learnt of the accident from the police, and at another that he learnt it from witnesses.
• He admitted that:
  • He did not know P.W.3 and P.W.4 personally (“a complete stranger”).
  • Neither he nor his children were present at the time of the accident.
  • He did not visit the spot of the accident.
• P.W.2 similarly admitted he did not witness the accident; his statement about the involvement of the lorry was based solely on what the police allegedly told him.

The Supreme Court endorsed the High Court’s view that both witnesses were unsure as to how the accident occurred and were “equally unsure about the involvement of the alleged offending vehicle” (para 14).

(b) Testimony of P.W.3 (Lokesh) and P.W.4 (Ravi)

P.W.3 and P.W.4 claimed to be eyewitnesses. Their evidence was crucial to bridge the gap between the accident and the alleged offending vehicle.

According to their examination-in-chief:

• They claimed that respondent no. 1 (driver) voluntarily approached them and confessed to having caused the accident.
• They further claimed that he disclosed the registration numbers of both vehicles involved.

The Tribunal found this story “inherently improbable and contrary to normal human conduct” (para 15), because:

• It is odd, in the ordinary course of events, that a driver would approach strangers and confess to a serious offence spontaneously, disclosing precise registration details.
• In cross-examination, both witnesses substantially undermined their earlier versions:
  • P.W.3 admitted he did not know who caused the accident.
  • P.W.4 admitted he did not know which vehicle was involved.

These contradictions led the Tribunal—and the Supreme Court—to hold that the supposed eyewitness account was unreliable and could not be safely relied upon as the basis for fixing liability.

4. Evaluation of Documentary Evidence

(a) FIR and Complaint

The FIR (First Information Report) and the initial complaint were relied upon by the appellants to establish:

• The occurrence of the accident.
• The later identification of the lorry and its driver, as ultimately led to a charge-sheet.

The Supreme Court clarifies a nuanced point (para 16):

• FIRs are not expected to be encyclopedic. Omission of the vehicle registration number in an FIR or complaint lodged immediately after the accident is not per se fatal.
• However, such omission must be considered along with other infirmities in the overall evidentiary picture (para 17).

In this case:

• The complaint only stated that a vehicular accident occurred, without identifying the offending vehicle.
• There was no clear, contemporaneous material indicating how the particular canter lorry was implicated.

(b) Spot Mahazar and Inquest Mahazar

The appellants relied on:

• The spot mahazar (a site inspection/panchnama prepared by the police),
• Recovery and inquest mahazars prepared during investigation, to show the locus of the accident and nature of impact.

The Supreme Court, however, noted (para 17):

• The spot mahazar was prepared several days after the accident, raising doubts as to its accuracy.
• There was no explanation or evidence showing:
  • On whose statement it was based, or
  • On what evidentiary foundation the police drew up those facts.

Given the absence of a clearly identified eyewitness or other direct evidence linking the vehicle to the accident, these documents were insufficient to establish vehicle involvement.

(c) Charge-Sheet

The appellants placed “strong reliance” on the filing of the charge-sheet against the driver (para 4, 6). The insurer’s counsel rightly contended that a charge-sheet should not be treated as “gospel truth” (para 9).

The Supreme Court implicitly accepts this position:

• A charge-sheet is a relevant piece of evidence but only as one factor in assessing the preponderance of probabilities.
• It cannot, by itself, substitute for independent judicial scrutiny of the evidence, especially when filed after considerable delay and when other evidence (such as the MVI report) undermines its factual basis.

Here, the vehicle was recovered one and a half months after the accident (para 10), and the charge-sheet appears to have been filed only thereafter. This temporal gap, combined with inconsistent witness testimony and a non-damaged vehicle, casts doubt on the charge-sheet’s probative force.

(d) Motor Vehicle Inspector’s Report (MVI Report)

The MVI report dated 05.10.2013 plays a pivotal role in the Court’s reasoning (para 18). It recorded:

• No damage whatsoever to the alleged offending vehicle.

Given that the accident was of such severity as to cause the deaths of two persons, the absence of any visible damage to the lorry was considered “wholly inconsistent” with the version advanced by the claimants.

The Court regards this as a strong negative indicator:

• If a heavy lorry had collided with a motorcycle with sufficient force to cause fatal injuries, some degree of physical damage (even if minor) to the lorry would ordinarily be expected.
• The MVI report thus undermines the prosecution/claimants’ theory of how the accident occurred and which vehicle was involved.

In the absence of any credible explanation for this inconsistency, the MVI report significantly weakened the claimants’ case.

5. Sympathy vs. Legal Principles

The Court acknowledges the tragic nature of the incident and expresses empathy (para 19):

“We are deeply conscious of the tragic loss suffered by the families of the deceased. The pain of losing young lives in their prime is immeasurable. However, the principles of law cannot be set aside on the grounds of sympathy alone.”

This reflects a recurring theme in motor accident jurisprudence: although the Motor Vehicles Act is a piece of beneficial legislation, intended to provide just compensation to victims, judicial determinations of liability must still be anchored in legal evidence and established principles.

The Court therefore reiterates that:

• Sympathy is not a substitute for proof of core facts such as vehicle involvement and negligence.
• Liability under the Motor Vehicles Act cannot be imposed in the absence of credible evidence, notwithstanding the hardship faced by victims’ families.

V. Impact and Implications

A. On Motor Accident Claims and Section 166 MV Act

This judgment sends a clear signal to claimants, Tribunals, and insurers about the evidentiary threshold for Section 166 claims:

• Claimants must be prepared to clearly establish three elements:
  1. The fact of the accident;
  2. Involvement of a specific vehicle and driver;
  3. Rash and negligent driving by that driver.
• While strict criminal-law standards are not applicable, courts will nevertheless scrutinize:
  • Witness consistency and credibility;
  • Corroboration between oral and documentary evidence;
  • Objective indicators like MVI reports and physical damage.
• Evidence such as FIRs, charge-sheets and mahazars are relevant but not conclusive; courts will weigh them in the context of all circumstances.

The decision, therefore, reinforces that Section 166 is fault-based and fact-intensive, requiring careful proof of who caused the accident and how.

B. On the Role of the Supreme Court under Article 136

The judgment underscores the limited review function of the Supreme Court in:

• MACT matters where both the Tribunal and the High Court have reached concurrent factual conclusions;
• Appeals that in substance amount to a request for re-appreciation of evidence without clear allegations of perversity.

After Collector Singh and this decision, it is even clearer that:

• The Supreme Court will seldom interfere with concurrent findings of fact in motor accident cases, unless there is demonstrable miscarriage of justice or gross misappreciation of evidence.
• Parties seeking relief under Article 136 must thus show more than mere disagreement with the lower courts’ conclusions; they must show that those conclusions are objectively unreasonable or unsupported by the record.

C. On Investigation Standards and Evidence-Gathering

Indirectly, the judgment highlights systemic issues:

• Delayed preparation of spot mahazars and failure to record or identify reliable eyewitness accounts can severely weaken a claimant’s case.
• Police investigation practices (e.g., late identification of the offending vehicle, mechanical inspection after long intervals) may lead to evidentiary gaps that courts cannot overlook.

For claimants and their counsel, the case underscores the importance of:

• Promptly gathering independent evidence (photographs, CCTV footage where available, witness statements);
• Ensuring that eyewitnesses are genuine, consistent, and credible;
• Seeking timely mechanical inspection of suspected vehicles.

D. For Insurers

From the insurer’s perspective, the judgment:

• Strengthens the proposition that they are not liable where vehicle involvement itself is doubtful;
• Confirms that they may legitimately challenge:
  • The identity of the offending vehicle, and
  • The credibility of delayed or contradictory evidence.

However, the judgment must not be read as a license for frivolous denial. The Court’s reasoning is strongly grounded in the specific facts—particularly the absence of damage and unreliable witness testimony.

VI. Complex Concepts Simplified

1. “Preponderance of Probabilities” vs. “Beyond Reasonable Doubt”

• Beyond reasonable doubt is the standard used in criminal cases. It requires the court to be almost certain of the accused’s guilt, leaving no reasonable doubt.
• Preponderance of probabilities is used in civil cases, including motor accident claims. It means that the version of facts put forward by one party is more likely to be true than the competing version. Absolute certainty is not required, but a reasonable level of confidence based on the evidence is.

In Sithara N.S., the Court reiterates that MACT proceedings use the civil standard, but that does not mean that any speculative version can be accepted.

2. “Concurrent Findings of Fact”

When both:

• The Trial Court/Tribunal, and
• The First Appellate Court/High Court

reach the same conclusion on facts (for example, both hold that a certain vehicle was not proved to be involved), these are called concurrent findings.

Under Article 136:

• The Supreme Court generally does not interfere with such findings merely to re-evaluate the evidence.
• Interference occurs only if those findings are perverse—meaning, clearly unreasonable, contrary to the evidence, or based on misreading of essential material.

3. “Mahazar” (Spot Mahazar, Inquest Mahazar, Recovery Panchanama)

• A mahazar is a written record prepared by the police, often in the presence of witnesses, describing what was observed at a scene (e.g., accident spot, recovery site) or what was seized.
• A spot mahazar records how the accident scene looked: position of vehicles, debris, bloodstains, tyre marks, etc.
• An inquest mahazar relates to the examination of a dead body, noting visible injuries and other circumstances of death.

These documents are useful in reconstructing what likely happened, but their evidentiary value depends on:

• How soon they were prepared after the incident;
• Who witnessed them and whether those persons are credible;
• Whether they are consistent with other evidence and physical facts.

4. “Sine Qua Non”

The insurer’s counsel described proof of vehicle involvement and negligence as sine qua non for a Section 166 claim (para 7).

“Sine qua non” is a Latin phrase meaning “an essential condition” or “something without which it cannot be”. In simple terms, if these elements are not proved, the claim cannot succeed.

5. Motor Vehicle Inspector’s (MVI) Report

• After a road accident, a Motor Vehicle Inspector may examine the vehicles involved and issue a report on their mechanical condition and visible damage.
• An MVI report can show:
  • Whether brakes or lights were in working order;
  • Extent and location of damage on the vehicle;
  • Any mechanical defects that might have contributed to the accident.

In this case, the MVI report showed no damage to the alleged lorry, which substantially weakened the claim that it had collided with the motorcycle.

VII. Conclusion

Sithara N.S. v. Sai Ram General Insurance Co. Ltd. reaffirms and applies a set of well-established but critically important principles in motor accident compensation jurisprudence:

• Fault-based liability under Section 166 MV Act requires proof of three essential elements: the accident, the involvement of a specific vehicle, and rash and negligent driving by its driver.
• The standard of proof is the civil standard—preponderance of probabilities—but credible and coherent evidence is still required, particularly to establish vehicle involvement.
• Documentary materials such as FIRs, charge-sheets, spot and inquest mahazars, and MVI reports are all relevant; however:
  • No single document is conclusive;
  • Courts must assess them as part of the overall evidentiary mosaic.
• The Supreme Court’s power under Article 136 to interfere with concurrent findings of fact is narrow and exceptional, as underscored by the reliance on Collector Singh v. L.M.L. Ltd. Unless those findings are perverse or based on gross misappreciation of evidence, they will be left undisturbed.
• The Court balances judicial sympathy for victims with a clear insistence on evidentiary discipline, refusing to let compassion override the requirement of proof.

In practical terms, the judgment is a cautionary reminder:

• To claimants and their counsel, that careful and credible evidence-gathering is indispensable;
• To investigating agencies, that delayed or incomplete investigation can fatally prejudice victims’ claims;
• To insurers, that their objections will be upheld where foundational facts are genuinely unproved.

In the broader legal context, Sithara N.S. is a significant reaffirmation that even within a welfare-oriented statutory framework, the rule of law requires proof, not presumption, before liability can be imposed. It thereby shapes how future courts will approach contested questions of vehicle involvement and negligence in motor accident claims.