An LMV licence authorizes driving transport vehicles below 7,500 kg without separate endorsement.

On 23 November 2013, an accident involving Pickup Vehicle No. MP-50-G-0347 resulted in the death of Roopchand, aged approximately 40 years.

His legal representatives filed a claim petition under Section 166 of the Motor Vehicles Act, 1988, seeking compensation of ₹23,26,666.

The Motor Accident Claims Tribunal, Balaghat, in Claim Case No. 47/2014, awarded ₹10,10,000 with interest by award dated 31 August 2016.

The claimants filed the present appeal under Section 173(1) of the M.V. Act, seeking enhancement of ₹1,00,000.

They also challenged the Tribunal’s exoneration of the Insurance Company on the ground that the deceased possessed only a Light Motor Vehicle (LMV) licence and lacked a separate endorsement to drive a transport vehicle.

Whether the Insurance Company could be exonerated merely because the deceased held an LMV driving licence without a separate endorsement authorising him to drive a transport vehicle?

Whether the claimants were entitled to enhancement of the compensation awarded by the Tribunal by ₹1,00,000?

The Court applied Section 173(1) of the Motor Vehicles Act, 1988, governing appeals against awards of the Claims Tribunal, and Section 166 concerning claims for compensation arising from motor accidents.

Relying on Mukund Dewangan v. Oriental Insurance Company Limited, (2017) 14 SCC 663, the Court held that a person holding an LMV licence is competent to drive a transport vehicle falling within the LMV class and does not require a separate endorsement.

The Court further relied on the Constitution Bench decision in Bajaj Alliance General Insurance Company Limited v. Rambha Devi & Others, (2025) 3 SCC 95, which affirmed Mukund Dewangan and held that an LMV licence under Section 10(2)(d) permits the holder to drive a transport vehicle having a gross vehicle weight below 7,500 kg without additional authorisation under Section 10(2)(e).

The Tribunal had exonerated the Insurance Company solely because the deceased did not possess a separate transport-vehicle endorsement.

Applying Mukund Dewangan, as affirmed by the Constitution Bench in Rambha Devi, the High Court held that this reasoning was legally unsustainable where the deceased admittedly held an LMV licence and the offending vehicle was insured.

The Insurance Company therefore could not avoid liability on that ground.

On quantum, considering the deceased’s age and income, the claimants’ dependency, and the material on record, the Court found that an additional amount of ₹1,00,000 would serve the ends of justice.

The compensation was enhanced from ₹10,10,000 to ₹11,10,000, and liability was fastened upon the respondent-Insurance Company.

The Insurance Company was directed to deposit ₹11,10,000 with interest at 6% per annum from the date of filing of the claim application until realisation, before the Claims Tribunal within 30 days.

The Tribunal was directed to disburse the amount according to the apportionment and other directions in the original award; the remaining terms of the award were left unaltered.