Raj Kumar Das (D) Thr. LRs. v. National Insurance Co. Ltd.
Background
In 2004, Raj Kumar Das, a 37-year-old brick-field labourer, was knocked down by a lorry and suffered 100% permanent disability (traumatic paraplegia). He filed a claim under Section 163A of the Motor Vehicles Act, but the Motor Accident Claims Tribunal dismissed it in 2007, holding that he had not proved the accident occurred, and the Calcutta High Court affirmed this dismissal in 2022. He died during the pendency of the case and was represented by his legal heirs before the Supreme Court.
Decision Breakdown
The Supreme Court held that the lower courts wrongly applied a "proof beyond reasonable doubt" standard instead of the correct "preponderance of probability" standard applicable to these summary, welfare-oriented proceedings, and found the accident and the claimant's injuries were reasonably established. Using its special powers under Article 142 of the Constitution, the Court departed from the strict formula under Section 163A and computed compensation instead using the broader principles applicable to claims under Section 166 (as laid down in Sarla Verma and Pranay Sethi), given the peculiar facts of the case, while clarifying this approach is not to be treated as a precedent. It set aside the Tribunal and High Court judgments, allowed the appeal, and directed the insurer to deposit Rs. 14,90,000/- with 6% interest from the date of filing the claim, within three months.
Lesson Learnt
Motor accident compensation claims are meant to be decided on a lenient "probability" standard, not a strict criminal-style proof standard, and lack of legal awareness by a genuine accident victim should not defeat a just claim once the basic facts are established.