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Mohar Sai and Anr. v. Gayatri Devi and Ors.

Civil Appeal · 2018 INSC 429Decided 27 Apr 2018
Civil Appeal No. 8411 of 2015
Chief Justice Dipak Misra · Justice A.M. Khanwilkar

Background

The deceased, Krishna Kumar Sahu, died after a motorcycle driven by the vehicle owner's son skidded and crashed while returning from a village visit; his widow, minor children, and parents filed a compensation claim under the Motor Vehicles Act. The Motor Accident Claims Tribunal awarded compensation without finding the deceased contributorily negligent, but the Chhattisgarh High Court partly reversed this, holding the deceased was 50% contributorily negligent and reducing the payable compensation after relying on the statements of the injured appellants. The vehicle owner and driver appealed to the Supreme Court, challenging the finding that the son had been driving and caused the accident through rash and negligent driving.

Decision Breakdown

The Supreme Court held that the High Court had committed a "manifest error" in reversing the Tribunal's factual finding by relying solely on the version of interested witnesses (the appellants themselves), while ignoring that the claimants' eyewitnesses were neither discredited nor contradicted during cross-examination. The Court found the Tribunal's conclusion, that the appellant's son was driving and caused the accident through rash and negligent driving, was consistent with the preponderance of probabilities and should not have been disturbed. Since the quantum difference between the Tribunal and High Court awards was only marginal, and the respondents had not themselves challenged the 50% contributory-negligence finding, the Supreme Court declined to interfere further under Article 136 and dismissed the appeal with no order as to costs.

Lesson Learnt

An appellate court should not overturn a trial tribunal's factual findings merely by preferring the version of interested, self-serving witnesses over independent eyewitnesses whose testimony remained unshaken in cross-examination: factual findings grounded in a sound weighing of evidence deserve deference.

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

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