The Supreme Court has ruled that while a delay in registering a First Information Report (FIR) cannot, on its own, justify rejecting a motor accident compensation claim, it becomes significant when other evidence casts doubt on the claimant’s version of events.
A bench comprising Justices Sudhanshu Dhulia and Ahsanuddin Amanullah addressed an appeal by New India Assurance Co. Ltd., challenging the Madras High Court’s decision to overturn the Motor Accident Claims Tribunal (MACT) ruling. The tribunal had previously dismissed a compensation claim, citing evidence that pointed to injuries from a scooter skid rather than a collision.
The case stemmed from a December 27, 2011 accident, where the claimant reported the incident to authorities 34 days later, on January 30, 2012. He sought ₹20 lakh in compensation, alleging a motor vehicle accident. However, medical records suggested that the injuries were consistent with a simple skid and fall. This, combined with the delayed FIR, led the MACT to reject the claim.
The High Court reversed this decision, ruling that a delayed FIR alone could not invalidate the claim. It awarded the claimant ₹11.5 lakh with interest at 7.5%, prompting the insurer to escalate the matter to the Supreme Court.
In its judgment, the Supreme Court clarified that a delayed FIR does not automatically disqualify a claim but gains relevance when corroborating evidence undermines the claimant’s allegations. The Court emphasized that in this instance, the police investigation concluded there was no motor accident, and a closure report was filed. These findings reinforced the MACT’s original decision to dismiss the claim.
The Supreme Court ultimately reinstated the tribunal’s decision, underlining that while procedural delays like a late FIR are not inherently fatal to a claim, they cannot be ignored when other evidence contradicts the claimant’s narrative.
The appeal was allowed, providing insurers and claimants clearer guidelines on how delayed FIRs interact with evidence in motor accident cases.
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