Supreme Court Rules Contributory Negligence Cannot Be Presumed Without Direct or Corroborative Evidence in Motor Accident Claims

In a recent landmark judgment, the Supreme Court of India emphasized that contributory negligence in motor accident claims cannot be presumed without direct or corroborative evidence. This ruling reinforces the necessity for concrete proof before attributing partial fault to victims in such cases.

The case in question involved a tragic incident where a 38-year-old man lost his life following a collision between his motorcycle and a Bangalore Metropolitan Transport Corporation (BMTC) bus. The Motor Accident Claims Tribunal initially awarded a compensation of ₹75,97,060 to the deceased's family. However, upon appeal, the Karnataka High Court attributed 25% contributory negligence to the deceased, reducing the compensation accordingly. The High Court's rationale was based on the assumption that both the deceased and the bus driver were driving at high speeds, leading to the accident.

Challenging this decision, the deceased's family approached the Supreme Court. The apex court scrutinized the evidence and found no direct or corroborative proof to support the High Court's claim of contributory negligence. The Supreme Court referenced its earlier decision in Jiju Kuruvila v. Kunjujamma Mohan (2013), where it was held that, in the absence of concrete evidence, it cannot be assumed that an accident occurred due to the rash and negligent driving of both vehicles involved. The Court reiterated that mere allegations or assumptions, without substantive evidence, are insufficient to establish contributory negligence.

Furthermore, the Supreme Court criticized the High Court's decision to reduce the deceased's monthly income assessment from ₹62,725 (as evidenced by a payslip) to ₹50,000 without valid justification. The apex court underscored that, under the Motor Vehicles Act, 1988, the strict rules of evidence applicable in criminal trials do not apply to compensation cases. This principle allows for a more lenient and victim-centric approach in civil matters related to motor accident claims.

Consequently, the Supreme Court set aside the High Court's findings on contributory negligence and the reduced income assessment. The Court enhanced the compensation by ₹1,20,84,925, providing substantial relief to the deceased's family. This judgment serves as a critical reminder that courts must rely on concrete evidence rather than conjecture when determining contributory negligence in motor accident claims. It ensures that victims or their families are not unjustly deprived of rightful compensation based on unfounded assumptions.

In essence, this ruling reinforces the judiciary's commitment to evidence-based adjudication, particularly in matters affecting the rights and compensations of accident victims. It highlights the importance of thorough and meticulous examination of facts before attributing fault, ensuring that justice is both served and seen to be served.