Legal Review and Analysis of Rajamma & Ors vs Ms Reliance General Insurance Co Ltd & Anr 2025 INSC 1176

1. Heading of the Judgment

Case Title: Rajamma & Ors. vs. M/s. Reliance General Insurance Co. Ltd. & Anr.
Citation: 2025 INSC 1176
Court: Supreme Court of India
Civil Appeal No.: 5172 of 2025
Judges: Justice K. Vinod Chandran and Justice N.V. Anjaria
Date of Judgment: September 26, 2025

2. Related Laws and Legal Principles

This judgment deals with the standard of proof required in motor accident claim cases. The key legal principles involved are:

• Motor Vehicles Act, 1988: Provides the framework for claiming compensation for death or injury arising from motor vehicle accidents.

• Preponderance of Probability: The standard of proof in civil cases, including motor accident claims. It means that a fact is considered proven if it is more likely to be true than not true. However, as this judgment clarifies, this standard is not a mere formality and must be applied rigorously when the evidence itself raises serious doubts.

• Burden of Proof: The initial burden lies on the claimants to establish that the death/injury was caused by a motor vehicle accident involving the offending vehicle. The testimony of witnesses must be credible and consistent to discharge this burden.

3. Basic Judgment Details

The appellants are the legal heirs (claimants) of a deceased person who allegedly died in a "hit-and-run" accident. The Motor Accidents Claims Tribunal (MACT) awarded them compensation of approximately Rs. 16 lakh, accepting their evidence. The High Court, however, reversed this decision, dismissing the claim petition after finding that the claimants failed to prove the accident itself and the involvement of the alleged vehicle. The claimants then appealed to the Supreme Court.

4. Core Legal Analysis: Scrutinizing the Evidence and Upholding the Standard of Proof

The core principle of this judgment is that the "preponderance of probability" standard is not a low threshold to be met by unreliable or contradictory evidence. The Court conducted a meticulous analysis of the claimants' evidence and found it riddled with improbabilities and inconsistencies that created a valid suspicion about the very occurrence of the accident as alleged.

A. The Central Issue

The Supreme Court was tasked with determining whether the High Court was correct in reversing the Tribunal's award by holding that the claimants failed to prove:

1. The fact of the motor vehicle accident.

2. The involvement of the specific vehicle insured by the respondent.

B. Analysis of Key Evidentiary Flaws

The Supreme Court agreed with the High Court's reasoning and identified several critical flaws in the claimants' case:

• The Unreliable FIR: The First Information Report (FIR) is a crucial document in establishing the initial version of events. In this case, the FIR was registered at a police station that had no jurisdiction over either the alleged accident spot or the place where the body was found. The transfer of the FIR to the correct police station happened after an unexplained delay of 117 days. The Court emphasized that no police official was examined to explain this irregularity, casting serious doubt on the authenticity and timeliness of the FIR.

• The Incredible Testimony of the Eyewitness (PW2): The entire case rested on the testimony of PW2, a neighbour who claimed to be an eyewitness. The Supreme Court found her testimony unbelievable for several reasons:
  Chance Witness: PW2 claimed to be running a fruit shop near the accident spot but produced no license or document to substantiate her presence there, making her a "chance witness" whose testimony requires strict scrutiny.
  Inherent Contradiction: PW2 stated that after the accident, she went to fetch the victim's daughter from a nearby school. Upon returning, both the offending vehicle and the victim had disappeared. However, she also claimed that she and the daughter had noted down the vehicle's number. The Court found this sequence of events logically impossible and self-contradictory.
  Non-examination of Material Witness: The victim's daughter, who was allegedly present and had noted the vehicle number, was not examined as a witness. This failure to examine a crucial witness weakened the case further.

• Suspicious Circumstances: The Court noted that the obituary card (Ext.P-13) produced by the claimants themselves indicated the date of death as June 20, 2014, whereas the alleged accident occurred on June 18, 2014. This created a discrepancy regarding the timeline of events. Furthermore, the driver of the alleged offending vehicle had been acquitted in the related criminal case, and PW2 (who was PW4 in the criminal case) had failed to identify him.

C. Application of the "Preponderance of Probability" Standard

The Supreme Court clarified that while claimants are not required to prove their case beyond a reasonable doubt (the criminal standard), the principle of preponderance of probability must be applied meaningfully. When the evidence presented by the claimants is itself unbelievable, contradictory, and raises valid suspicions about the truth of the claim, it fails to meet even the civil standard of proof. The Court held that the High Court was correct in concluding that the evidence did not tilt the balance of probability in favour of the claimants.

5. Final Outcome and Supreme Court's Directions

The Supreme Court found no infirmity in the well-reasoned judgment of the High Court. Consequently, the appeal was dismissed.

Direction: The Supreme Court upheld the decision of the High Court, which had set aside the award of compensation granted by the Tribunal. As a result, the claimants (appellants) were not entitled to any compensation.

6. MCQs Based on the Judgment

Question 1: In the case of Rajamma & Ors. vs. Reliance General Insurance Co. Ltd. (2025 INSC 1176), on what primary ground did the Supreme Court dismiss the claimants' appeal?

a) The offending vehicle was not insured at the time of the accident.
b) The claimants failed to prove the involvement of the alleged vehicle in the accident due to unreliable and contradictory evidence.
c) The compensation amount awarded by the Tribunal was excessively high.
d) The accident was caused solely by the negligence of the deceased.

Answer: b) The claimants failed to prove the involvement of the alleged vehicle in the accident due to unreliable and contradictory evidence.

Question 2: The Supreme Court, in the Rajamma case, emphasized that the standard of "preponderance of probability" requires?

a) Proof beyond any shadow of a doubt, similar to a criminal trial.
b) Evidence that is completely flawless and without any minor discrepancies.
c) Evidence that makes the claim more likely true than not, and cannot be based on testimony that is inherently unbelievable.
d) An FIR that is registered without any delay whatsoever.

Answer: c) Evidence that makes the claim more likely true than not, and cannot be based on testimony that is inherently unbelievable.