Claim Petitions Under Section 166(3) Motor Vehicles Act Cannot Be Dismissed For Limitation Pending Supreme Court Adjudication

This judgment resolves a batch of civil revisions filed by various Insurance Companies and vehicle owners (Applicants) against orders passed by different Motor Accident Claims Tribunals (MACT).

The claimants (Non-Applicants) had instituted claim petitions under Section 166 of the Motor Vehicles Act, 1988 (M.V. Act) for accident-related injuries, but these petitions were filed beyond the statutory limitation period prescribed under Section 166(3) of the Act.

The Applicants filed objections and applications under Order 7 Rule 11 of the CPC, seeking rejection of the claims as time-barred.

The respective Tribunals rejected these objections, condoned the delay by applying principles analogous to Section 5 of the Limitation Act, 1963, and proceeded with the cases.

The Applicants challenged these orders, asserting that the MACT is a statutory body with no power to condone delay under the current amended provisions of the M.V. Act.

1. Whether the Motor Accident Claims Tribunal has the jurisdiction to condone delay in filing claim petitions under Section 166 of the M.V. Act post-amendment.

2. Whether the claim petitions filed beyond the limitation period prescribed under Section 166(3) are liable for rejection at the threshold under Order 7 Rule 11 of the CPC.

Section 166(3) of the Motor Vehicles Act, 1988, which governs the limitation period for filing claim petitions.

Section 5 of the Limitation Act, 1963, regarding the condonation of delay for sufficient cause.

The Court relied on binding interim directions from the Hon’ble Supreme Court in ICICI Lombard General Insurance Company Limited v. Ayiti Navaneetha and others (SLP (C) Nos. 8412–8413/2023) and Bhagirathi Dash v. Union of India and another (W.P. (C) No. 166/2024).

These precedents established that Tribunals and High Courts must not dismiss claim petitions solely on the grounds of limitation under Section 166(3) while the issue of the condonability of such delay remains under active consideration by the Apex Court.

The High Court noted that the Applicants’ primary grievance was that the MACT, as a statutory forum, cannot travel beyond the express provisions of the M.V. Act, which currently lacks a provision for condoning delay in Section 166(3).

The Court observed that the Supreme Court has issued specific interim stay orders in similar proceedings, directing that claims should not be dismissed on limitation grounds at this stage.

The Court reasoned that a balanced approach was necessary to prevent claimants from being non-suited on technicalities while the law is in flux.

It held that the Tribunals did not commit a jurisdictional error by entertaining the petitions, as they were effectively following the spirit of the Supreme Court's interim mandates.

To safeguard the interests of the Insurance Companies and owners, the Court determined that while the proceedings may continue, the passing of a final award must be stayed until the Supreme Court settles the legal controversy.

The Court held that the claim petitions cannot be rejected at the threshold on the ground of limitation at this stage.

It directed the concerned MACTs to proceed with the adjudication of the claims on merits but ordered that no final award shall be passed until the Hon’ble Supreme Court conclusively decides the issue of limitation under Section 166(3) of the M.V. Act.

All contentions regarding jurisdiction and limitation remain open for the parties to argue at a later stage.

Any existing interim orders were vacated subject to these directions.