The Supreme Court reversed the Madhya Pradesh High Court's order that set aside an award by the Motor Accident Claims Tribunal (MACT). The appeal, brought by Geeta Dubey and her family, involved compensation for the death of Chakradhar Dubey in a motor vehicle accident. The Court stressed the need for evidence to be evaluated on the preponderance of probabilities in claim cases and found the High Court's summary order insufficient.

Background of the Case

The claimants, wife and son of the deceased Chakradhar Dubey, sought compensation for his death caused by a road accident involving a truck. The MACT awarded ₹50,41,289, but the High Court overturned this on grounds of insufficient evidence regarding the truck's involvement.

Factual Details

1. The Incident
   On 18.06.2018, Chakradhar Dubey was in a car that was hit by a truck near Sonwari Toll Plaza, Madhya Pradesh. He sustained serious injuries and later succumbed on 28.06.2018.

2. Police Investigation
   An FIR was filed under Sections 279 and 337 of IPC on 21.06.2018. Initial investigations concluded the involvement of an unknown vehicle, later identified as Truck MP-19-HA-1197 based on witness statements.

3. Claim and Tribunal Findings
   The claimants sought ₹59,30,000 in compensation. The MACT relied on eyewitness testimony and police records to establish the truck’s involvement and the driver’s negligence.

4. High Court's Reversal
   The High Court found delays in evidence collection and gaps in proving the truck's involvement, leading to the annulment of the MACT award.

Acts and Sections Discussed:

1. Motor Vehicles Act, 1988

   • Section 133: Responsibility of the vehicle owner to disclose driver details.
   • Section 173: Appeal provisions.

2. Indian Penal Code (IPC)

   • Section 279: Rash driving or riding on a public way.
   • Section 337: Causing hurt by an act endangering life or personal safety.

Evidence Act, 1872

• Section 106: Burden of proving facts within special knowledge.

Ratio Decidendi:

1. Standard of Proof in Claim Cases: The claimants need to prove involvement based on the preponderance of probabilities, not beyond reasonable doubt.
2. Duty of Appellate Courts: Appeals under Section 173 require detailed evaluation of all evidence, including oral and documentary, especially when overturning a tribunal’s well-reasoned decision.
3. Delay Justified by Circumstances: Delays in evidence submission due to genuine hardship (death of a family member) do not undermine credibility.

Subjects:

Motor Accident Claim, Judicial Review
MACT Award, Supreme Court, Motor Vehicles Act, Compensation, Judicial Reversal, Claim Cases, Evidence Evaluation