Civil revision against low-value motor accident awards is maintainable only in exceptional circumstances of irreparable injury.

The Insurance Company (Petitioner) filed a civil revision under Section 115 of the CPC challenging a Claims Tribunal award dated December 23, 2025.

The Tribunal awarded Rs. 74,057 to the claimant but found the vehicle was operated in breach of policy conditions; nonetheless, it directed the Petitioner to "pay and recover" the amount.

The Petitioner contended that following the 2019 amendment to the Motor Vehicles Act, which renumbered Section 149 to Section 150, the provision allowing "pay and recover" (formerly Section 149(4)) was removed.

The Petitioner argued that liability should have been imposed solely on the owner.

The Court noted that the award amount was significantly below the statutory threshold for appeals.

The court applied Section 173(2) of the Motor Vehicles Act, 1988 (as amended in 2019), which bars appeals against awards where the amount in dispute is less than Rs. 1,00,000.

It relied on the Special Bench decision in National Insurance Company v. Shrikant Vinod Tiwari and others (2007), which held that while a revision under Section 115 CPC may lie on limited grounds (e.g., jurisdictional error or failure of justice), it cannot be used to bypass statutory bars on appeals.

The court also cited Nirbhai Singh and another v. Darshan Singh @ Darshan Singh and others (2025), which deprecated the practice of using revisional or supervisory jurisdiction to circumvent the statutory prohibition on appeals for low-quantum awards.

The Court reasoned that while the 2007 Special Bench in Shrikant Vinod Tiwari allowed revisions in exceptional circumstances—such as jurisdictional excess or irreparable injury—the Petitioner failed to meet this threshold.

The Court observed that the legal question regarding Section 150 is currently being litigated in numerous appeals before various High Courts and the Supreme Court; thus, the Petitioner faces no irreparable injury or finality of legal prejudice if this specific low-value award remains unchallenged.

Furthermore, the Court noted that the litigation expenses for this revision would likely equal or exceed the awarded compensation of Rs. 74,057, making the pursuit of the revision commercially and procedurally disproportionate.

Consequently, the Court found no "failure of justice" or "irreparable loss" necessitated by the Tribunal's direction of "pay and recover" in this specific instance.

The Court held that the Petitioner cannot circumvent the statutory bar under Section 173(2) for awards under Rs. 1,00,000 unless exceptional grounds are met.

The legal issues regarding the interpretation of Section 150 were left open for determination in pending cases.

The Court granted the Petitioner liberty to restore the revision only if the claimant files for an enhancement of the award.