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Sanju Bai Prajapati & Ors. v. The New India Assurance Company Ltd. & Ors.

Civil Appeal · 2025 INSC 823Decided 14 Jul 2025
Civil Appeal arising out of SLP (C) No. 13455 of 2023
Justice Sudhanshu Dhulia

Background

A school peon died after his motorcycle was hit by a speeding vehicle. His wife and three minor children were awarded about Rs. 46.29 lakh in compensation by the Motor Accident Claims Tribunal. On appeal by the insurance company, the High Court set aside the award, doubting that the identified offending vehicle was really involved: largely because the FIR was registered three months after the accident and an eyewitness could not recall exact details like the vehicle's colour or number plate style.

Decision Breakdown

The Supreme Court found the High Court's reasoning unconvincing. A hospital "Murg" report (a police record made when an unnatural death is reported) was filed on the very day of the accident, confirming the incident occurred as described, and the subsequent police investigation, triggered by that report, was what led to the eyewitness being identified and the FIR eventually being registered. The Court held that minor inconsistencies in an eyewitness's memory of vehicle details, and a delay in filing the FIR that was explained by the investigation timeline, were not sufficient grounds to disbelieve the claim, especially since the insurance company never bothered to examine the investigating officer to challenge the FIR's authenticity. The Tribunal's compensation award was restored in full.

Lesson Learnt

Courts should not let minor gaps in an eyewitness's memory or a reasonably explained delay in filing an FIR defeat a genuine compensation claim for an accident victim's family, especially where independent evidence like a hospital report corroborates that the accident occurred as described.

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

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