Summary of Judgment Sanju Bai Prajapati & Ors. vs. The New India Assurance Company Ltd. & Ors.

Related Law:

Motor Vehicles Act, 1988 (Dependency claims in fatal accidents)

Citation: 2025 INSC 823
Case Title: Sanju Bai Prajapati & Ors. vs. The New India Assurance Company Ltd. & Ors.
Civil Appeal No.: 9466 of 2025 (@ SLP (C) No. 13455 of 2023)
Court: Supreme Court of India
Judges: Hon’ble Mr. Justice Sudhanshu Dhulia & Hon’ble Mr. Justice K. Vinod Chandran
Date of Judgment: 14th July 2025

Background

1. Accident & Claim:
   Deceased, a school peon, died in a motorcycle accident while returning home. The motorcycle collided with a speeding vehicle.
   Claimants (wife and three minor children) filed for compensation. The Tribunal awarded ₹46,29,152/- (against claimed ₹53,79,820/-).
   Insurance Company appealed, disputing involvement of the offending vehicle and citing delayed FIR (registered 3 months post-accident).

2. High Court’s Decision:
   Set aside Tribunal’s award, doubting eyewitness testimony and vehicle involvement due to:
   Eyewitness (PW-2) could not recall vehicle color/registration details.
   FIR delay (3 months) deemed suspicious.

Issues Before the Supreme Court

1. Whether the High Court erred in disbelieving eyewitness testimony and dismissing the claim.

2. Whether the delay in FIR registration invalidated the accident’s occurrence.

3. Whether the Tribunal’s award deserved restoration.

Supreme Court’s Decision

1. Eyewitness Credibility:
   Rejected High Court’s view: Minor discrepancies (e.g., vehicle color) do not negate eyewitness account.
   Evidence Supported:
   Murg report confirmed accident timing (6 PM) and death (12:30 AM) on the same day.
   FIR was based on investigation triggered by the Murg report.

2. FIR Delay:
   Not fatal: Delay due to witness belatedly approaching police does not disprove accident.
   Insurance Company’s lapse: Failed to examine investigating officer to contest FIR’s validity.

3. Restoration of Tribunal’s Award:
   Compensation: Directed insurer to pay ₹46,29,152/- with interest within 2 months.
   Disbursement:
   Equal shares to wife and three minors.
   Minors’ shares to be held in fixed deposits (interest accessible to mother/guardian).

Conclusion

• The Supreme Court allowed the appeal, restoring the Tribunal’s award and emphasizing:
  Eyewitness testimony cannot be dismissed for trivial inconsistencies.
  Delayed FIR is not conclusive proof of fabrication.
  Insurance companies must substantiate defenses with evidence.

Final Direction:

• Insurer to comply with payment directions; pending applications closed.