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

I. Case Identification & Vitals

1. Court: Supreme Court of India
2. Case Title: Sanju Bai Prajapati & Ors. vs. The New India Assurance Company Ltd. & Ors.
3. Document Type and Date of Judgment: Judgment, July 14, 2025
4. Case Number: Civil Appeal No. ___ of 2025 (@ Special Leave Petition (C) No.13455 of 2023)
5. SCR Citation: NA
6. Neutral Citation: 2025 INSC 823
7. Disposal Nature: Appeal Allowed
8. Case Type: Civil Appeal
9. Law Applicable: Motor Vehicles Act, Civil Procedure
10. Bench:

1. Hon’ble Justice Sudhanshu Dhulia
2. Hon’ble Justice K. Vinod Chandran
   11. Judgment Authored by: Hon’ble Justice K. Vinod Chandran*

II. Summaries & Core Issues

12. Headnote:
In Sanju Bai Prajapati vs. The New India Assurance Company Ltd., the Supreme Court reversed a High Court ruling that had denied compensation to the widow and minor children of a deceased accident victim. The Tribunal had granted Rs. 46,29,152/- based on credible eyewitness testimony and valid documentation. The High Court, however, questioned the delay in filing the FIR and inconsistencies in the witness statement. The Supreme Court held that the FIR delay was explained by the Murg report filed on the same day, and that the High Court had unjustly discredited the witness. The order of the High Court was set aside, and compensation reinstated. (Drafted Summary)

13. Short Summary:
The Supreme Court reinstated compensation of Rs. 46.29 lakhs to the widow and children of an accident victim, finding that the High Court erred in rejecting valid evidence and questioning FIR delay.

14. Issue for Consideration:
Whether the delay in registering the FIR and inconsistencies in the eyewitness’s account were sufficient grounds for the High Court to set aside the compensation awarded by the Tribunal.

III. Procedural & Factual Background

15. Case Start Date: NA
16. Case Arising From:
The matter arose from the High Court’s reversal of a Motor Accident Claims Tribunal award which had granted compensation to the claimants. The High Court doubted the involvement of the vehicle due to delay in the FIR and minor inconsistencies in witness testimony.

17. Background and Facts:
The deceased, employed as a peon in a school, died after being hit by a speeding vehicle while riding his motorcycle. A Murg report was filed the same day at the hospital. The FIR was registered three months later after further investigation. An eyewitness (PW-2) testified to the accident but could not precisely recall the vehicle’s registration number and color, leading the High Court to discredit his testimony. The Supreme Court found the High Court’s assessment flawed and upheld the Tribunal’s compensation order.

18. Timeline:

• Accident Date: Unspecified (evening at 6 PM)
• Same Day: Murg report filed by hospital (Annexure P-1)
• FIR Filed: Three months later (Annexure P-2)
• Tribunal Award: Rs. 46,29,152/- compensation granted
• High Court: Set aside the award
• July 14, 2025: Supreme Court reinstated the Tribunal’s award

19. Parties Involved:

• Appellants: Sanju Bai Prajapati (widow), three minor children of the deceased
• Respondents: The New India Assurance Company Ltd. & Ors.

20. Procedural History:

• Tribunal: Granted Rs. 46,29,152/- as compensation
• High Court: Set aside Tribunal’s award citing unreliable witness and FIR delay
• Supreme Court: Reinstated compensation and reversed High Court’s findings

IV. Legal Analysis & Arguments

21. Issues Framed: Not Applicable
22. Areas of Debate:

1. Whether a delayed FIR undermines the legitimacy of a motor accident claim.
2. Can minor inconsistencies in an eyewitness’s testimony justify overturning a compensation award?

23. Cases Cited by Petitioner/Appellant: NA
24. Cases Cited by Respondent/Defendant: NA

25. Acts/Rules/Orders Referred:

• Motor Vehicles Act, 1988
• General principles of evidence under the Indian Evidence Act

26. Acts/Rules/Orders Governing the Case: Motor Vehicles Act, 1988
27. Literature Citation: NA

28. Appearances for Parties:

• Advocates: Not named in the judgment
• Witnesses: PW-2 (eyewitness to the accident)
• Other Persons: NA

29. Prayer: To reinstate the compensation awarded by the Motor Accident Claims Tribunal

30. Evidence & Findings:

1. Evidence: Eyewitness (PW-2) testimony
   Findings: Found credible by Tribunal; unjustly discredited by High Court
2. Evidence: Murg report and FIR
   Findings: Murg report filed on day of accident; delay in FIR was satisfactorily explained
3. Evidence: Vehicle documents
   Findings: Valid and seized by police; no violation of insurance policy found

31. Petitioner/Appellant Arguments:

1. FIR delay explained through Murg report filed on accident day
2. Eyewitness was consistent and credible in narrating the event
3. Compensation based on reasonable assessment of deceased’s income and dependency

32. Respondent/Defendant Arguments:

1. FIR delay casts doubt on vehicle’s involvement
2. Eyewitness testimony lacks key details (registration number, color, etc.)

V. Judgment & Conclusion

33. Ratio Decidendi:

1. Delay in FIR does not invalidate claim when explained through hospital Murg report
2. Tribunal’s finding based on PW-2’s testimony was logical and should not have been interfered with
3. Insurance company failed to examine IO or rebut evidence effectively

34. Final Decision: The appeal is allowed. The High Court’s order is set aside. The Tribunal’s award of Rs. 46,29,152/- with interest is reinstated and must be disbursed to the claimants within two months.

35. Legal Jargons and Maxims:

• Murg Report: Preliminary record of unnatural death registered by police upon hospital intimation
• FIR: First Information Report, often foundational in criminal and accident-related claims
• Preponderance of Probability: Standard of proof in civil cases, requiring more probable than not

36. Exhibits: []

VI. Key Learnings for Law Students and Legal Professionals

This judgment reiterates that delay in lodging an FIR cannot be used to deny compensation where the death and accident are otherwise established by contemporaneous reports and credible testimony. It stresses the importance of a humanitarian approach in accident claim disputes.

Important Keywords for the Judgment: Sanju Bai Prajapati vs The New India Assurance Company Ltd.

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