ICICI Lombard General Insurance Company Ltd. Vs. Rajani Sahoo & Ors. [Civil Appeal No. of 2025 @ SLP (C) No. 29302 of 2019]
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India, in ICICI Lombard General Insurance Company Ltd. vs. Rajani Sahoo & Ors. [Civil Appeal No. of 2025 @ SLP (C) No. 29302 of 2019], delivered its judgment on January 2, 2025, upholding the compensation awarded to the legal heirs of Udayanath Sahoo, who died in a motor vehicle accident.
Facts and Background
Udayanath Sahoo was riding a motorcycle when a truck bearing registration No. OR-04-D-5675, insured with ICICI Lombard, collided with the rear of his motorcycle on April 27, 2019. The impact caused the motorcycle to crash into a tree, resulting in Udayanath’s death and severe injury to the pillion rider. An FIR was registered (No. 61/2009 at Police Station Sarankul), and the legal heirs filed a claim under Section 166 of the Motor Vehicles Act, 1988, seeking compensation of ₹10,50,000.
The Motor Accidents Claims Tribunal (MACT), Nayagarh, awarded ₹6,77,164 with 7% interest per annum from the date of filing the claim. ICICI Lombard challenged this award, contending that the accident was caused solely due to the deceased’s negligence and alleged that the police chargesheet was fabricated in connivance with the claimants.
Legal Issues
The Supreme Court examined:
Whether the evidence, including police records such as FIR and final report, could be relied upon to establish negligence.
The insurer’s allegation of fraudulent chargesheet and connivance between claimants and police.
The correctness of the Tribunal and High Court’s findings on negligence and liability.
Court’s Analysis and Findings
The Court held that the Tribunal rightly considered oral and documentary evidence, including the FIR, final report, and eyewitness testimony, to conclude that the truck driver was rash and negligent. The final police report found the driver guilty of rash and negligent driving causing death.
The Court rejected the insurer’s allegation of collusion and fabrication, noting that the appellant failed to prove any such conspiracy. It emphasized that police records admissible before the Tribunal for determining negligence cannot be discarded merely on suspicion.
The Supreme Court found no perversity or illegality in the concurrent findings of the Tribunal and High Court and held that the claimants were entitled to compensation.
Conclusion
The Supreme Court dismissed ICICI Lombard’s appeal, affirming the compensation awarded to the deceased’s legal heirs. The judgment clarifies that:
Police records such as FIR and final report are admissible and relevant evidence in motor accident claims.
Allegations of fabricated chargesheets require clear proof, failing which the Tribunal’s findings stand.
Negligence must be established on the basis of evidence before the Tribunal, not merely on conjecture.
This ruling reinforces the protective framework for victims of motor accidents and confirms the judiciary’s approach to relying on comprehensive evidence, including police investigations, to determine liability and award compensation.
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