Suhagrani and Others v. Manager, Cholamandalam MS General Insurance Co. Ltd.
Background
The husband/father of the appellants died after his motorcycle was allegedly hit from behind by a mini-truck, and his family sought compensation of about Rs. 1.88 crore before the Motor Accident Claims Tribunal (MACT) in Madhya Pradesh. The Tribunal accepted their case and awarded Rs. 12,43,324 with 6% interest, relying on the widow's eyewitness testimony and documents including the FIR, death report and final police report. The insurance company appealed, arguing the deceased had simply lost balance and fallen, pointing to a police statement attributed to the deceased's son (who was following behind) that supposedly said so. The Madhya Pradesh High Court accepted this argument, set aside the tribunal's award, and dismissed the claim entirely, prompting the family to appeal to the Supreme Court.
Decision Breakdown
The Supreme Court held that the High Court had erred by relying on the son's alleged police statement even though he had denied giving any such statement when cross-examined at trial, and the police officer who supposedly recorded it was never examined to prove its contents, so it should not have been used to override the tribunal's findings. The Court emphasized that the widow, who was riding pillion and witnessed the accident firsthand, was the best available witness, and her delay in filing a complaint was understandable given she was occupied trying to save her husband's life across multiple hospitals. It also noted the insurer never challenged the chargesheet filed against the offending vehicle's driver, reinforcing that the accident did occur as claimed. On quantum, the Court declined to enhance compensation for claimed agricultural income (unsupported by documentary evidence, and the land itself remained with the family), but modified the apportionment so the widow receives 85% and the three adult children share the remaining 15% equally, restoring the tribunal's compensation amount.
Lesson Learnt
In accident compensation claims, an eyewitness's direct testimony at trial carries more weight than an unproven, later-retracted statement recorded by police during investigation; and appellate courts should be cautious about overturning a tribunal's factual findings based on evidence that was never properly proved through examination of the person who recorded it.