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ICICI Lombard General Insurance Co. Ltd. v. Rajani Sahoo & Ors.

Civil Appeal · 2025 INSC 6Decided 2 Jan 2025
Civil Appeal No. 22 of 2025 (arising from SLP(C) No. 29302 of 2019)
Justice C.T. Ravikumar · Justice Rajesh Bindal

Background

Udayanath Sahoo died after the motorcycle he was riding was hit from behind by a truck insured with the appellant, ICICI Lombard, causing him to crash into a roadside tree. His legal heirs claimed compensation under Section 166 of the Motor Vehicles Act, and the Motor Accidents Claims Tribunal awarded them Rs. 6,77,164 with 7% interest, holding the truck driver's rash and negligent driving responsible based on the FIR, the police final report (which held the truck driver guilty), and eyewitness testimony. The High Court of Orissa dismissed the insurer's appeal, and ICICI Lombard approached the Supreme Court, alleging the chargesheet had been fraudulently prepared by the claimants in connivance with the police.

Decision Breakdown

The Supreme Court reaffirmed settled principles that in motor accident claims, negligence must be proved on the touchstone of "preponderance of probability," not the criminal standard of proof beyond reasonable doubt, and that a duly filed police chargesheet/final report is legitimate and admissible evidence for this purpose, relying on its own earlier decisions in Mangla Ram v. Oriental Insurance Co. Ltd. and Mathew Alexander v. Mohammed Shafi. Since both the Tribunal and the High Court had concurrently relied on the FIR, final report, and oral evidence to find the truck driver at fault, and the insurer's bare allegation of police-claimant collusion was never actually proved, the Court found no perversity warranting interference and dismissed the appeal, upholding the compensation award.

Lesson Learnt

In motor accident compensation cases, courts do not apply a strict "beyond reasonable doubt" standard: the police chargesheet and final investigation report can be relied upon to establish negligence on a balance of probabilities, and an insurer alleging fraud or collusion must actually prove it, not merely assert it.

Official source (sci.gov.in)View Judgment (PDF)

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