A Claims Tribunal cannot dismiss a motor accident claim solely for defects in minor representation.

The appellant/claimant filed a claim petition under Section 166 of the Motor Vehicles Act, 1988, seeking compensation of ₹3,15,000 for injuries sustained in a motorcycle accident dated 5 July 2018.

The motorcycle allegedly struck the claimant while he was standing near a house in Village Amdad, District Sidhi. Ankit Gupta, described as a minor driver, was impleaded through his natural guardian and father, Ramvishwas Gupta; the vehicle was owned by Ramvishwas Gupta and insured by United India Insurance Company Limited.

The First Motor Accident Claims Tribunal, Sidhi, dismissed the claim on 11 March 2026 on the ground that the claimant had not complied with Order XXXII CPC concerning representation of the minor driver.

The claimant appealed under Section 173(1) of the MV Act, contending that the claim petition itself disclosed representation through the minor’s father, that no direction to cure any procedural defect had been issued, and that Order XXXII CPC was not among the CPC provisions expressly made applicable by Rule 240 of the Madhya Pradesh Motor Vehicles Rules, 1994.

By the time of the Tribunal’s award, the minor respondent had attained majority.

Whether the Claims Tribunal could dismiss a claim petition under Section 166 of the MV Act solely for alleged non-compliance with Order XXXII CPC concerning the representation of a minor respondent, particularly when the minor was described as represented through his natural guardian?

Whether Order XXXII CPC was mandatorily applicable to proceedings before the Claims Tribunal in view of Rule 240 of the Madhya Pradesh Motor Vehicles Rules, 1994?

Whether, even if further representation of the minor was required, the Tribunal was justified in dismissing the substantive compensation claim without granting an opportunity to cure the defect or securing proper representation itself?

Whether the Tribunal could avoid deciding the issues of negligence, entitlement, quantum and insurer liability after dismissing the claim on the procedural ground?

A claim before a Motor Accident Claims Tribunal is a statutory inquiry under Chapter XII of the MV Act and is neither an ordinary civil suit nor a traditional adversarial proceeding; the Tribunal must adopt a summary and efficacious procedure directed towards determining “just compensation,” as held in United India Insurance Co. Ltd. v. Shila Datta, (2011) 10 SCC 509.

The MV Act is beneficial legislation, and procedural technicalities should not defeat the compensation remedy, as recognised in Vimla Devi v. National Insurance Co. Ltd., (2019) 2 SCC 186, and Rajo Devi v. Manjeet Kaur, 2025 INSC 741.

Rule 240 of the Madhya Pradesh Motor Vehicles Rules, 1994 specifies the CPC provisions applicable to Tribunal proceedings and does not expressly include Order XXXII CPC.

Under Order XXXII Rule 3 CPC, where a minor defendant is not properly represented, the Court must secure appropriate representation; the provision does not authorise dismissal of the substantive proceeding merely because a formal guardianship order was not obtained.

Proper representation through a natural guardian may be sufficient where there is no adverse interest or prejudice, while the Tribunal must intervene if the minor’s interests are inadequately or adversely represented.

Rule 238 of the MP Motor Vehicles Rules also requires the Tribunal to record findings and reasons on the issues arising for determination.

The High Court held that the Tribunal proceeded on an erroneous assumption that formal compliance with Order XXXII CPC was mandatory, without first examining Rule 240 or the special statutory character of MACT proceedings.

The claim petition expressly described Ankit Gupta as a minor represented through his father, Ramvishwas Gupta, and there was no finding that the father was unwilling, incompetent or had interests adverse to the minor.

If the Tribunal considered the representation inadequate, its duty was to direct the parties to cure the defect or to secure proper representation of the minor; it could not dismiss the injured claimant’s substantive claim without notice or opportunity.

The Tribunal’s approach was particularly unsustainable because the minor had attained majority before the award, requiring the Tribunal to recognise the change in status and provide him an opportunity to participate in his own capacity.

Further, dismissal on the procedural issue left the material issues of negligence, compensation, quantum and insurance liability undecided, contrary to Rule 238.

It restored the claim petition to its original number and remanded it to the Claims Tribunal for fresh adjudication in accordance with law, clarifying that no opinion was expressed on the merits of the claim.

The Tribunal was directed to endeavour to decide the matter preferably within six months and the parties were directed to appear before it on 23 September 2026.