Civil Revision Against Low-Quantum Motor Accident Awards Not Maintainable Solely to Settle Questions of Law

Shriram General Insurance challenged an award passed by the Claims Tribunal, which granted ₹15,000 compensation to the claimant

The Tribunal found the vehicle was operated in breach of policy conditions but applied the "pay and recover" principle against the insurer

The petitioner argued that following the 2019 Amendment to the Motor Vehicles Act (specifically the renumbering of Section 149 to Section 150), the "pay and recover" provision no longer exists, and liability should rest solely on the vehicle owner

The petitioner field a Revision under Section 115 CPC because Section 173(2) of the Act bars appeals for awards below ₹1,000,000

1. Whether an Insurance Company can maintain a revision petition under Section 115 of the CPC against a low-quantum award where a statutory appeal is barred by Section 173(2) of the Motor Vehicles Act

2. Whether the legal importance of interpreting the amended Section 150 of the Motor Vehicles Act justifies entertaining a revision despite the trivial compensation amount

Section 173(2) of the Motor Vehicles Act, 1988 (as amended in 2019), which prohibits appeals against awards where the amount in dispute is less than ₹1 Lakh

Special Bench precedent in National Insurance Company v. Shrikant Vinod Tiwari (2007), which held that while a revision under Section 115 CPC is not absolutely barred, it is limited to cases of jurisdictional error, failure of justice, or irreparable injury

Nirbhai Singh v. Darshan Singh (2025) from the Punjab and Haryana High Court, which deprecated circumvention of statutory appeal bars through Article 227 or revision petitions

The Court observed that while the petitioner raised a substantive legal question regarding "pay and recover" under the amended Section 150, this issue is already pending in numerous other litigations before various High Courts and the Supreme Court

Consequently, the petitioner would not suffer "irreparable injury" or a "failure of justice" if this specific revision were dismissed, as the legal point would be settled elsewhere

The Court noted that the litigation cost of the revision would likely exceed the actual award of ₹15,000, rendering the exercise financially counterproductive and an abuse of the court's process

It held that the Special Bench's allowance for revisions was intended for "special circumstances," not as a routine alternative to a barred appeal

It held that the Insurance Company failed to demonstrate that the award would cause irreparable loss or was a result of fraud

The Revision was dismissed, though the legal issues were left open for determination in other pending cases

The Court granted liberty to the petitioner to restore the revision only if the claimant files for enhancement of compensation