Driver holding tractor license is legally authorized to drive light motor transport vehicles.

The husband of Respondent No. 1, Abhay Singh, was employed as a driver by Respondent No. 4 (owner) for a tempo (Vikram)

On 30.11.2004, the deceased succumbed to injuries sustained in an accident involving said vehicle.

The claimants filed for compensation under the Workmen’s Compensation Act, 1923, asserting a monthly salary of Rs. 4,000/-

The employer admitted the employment and salary, while the Appellant-Insurance Company contested the employment relationship, the quantum of income, and the validity of the deceased’s driving license, which was specifically for a "tractor"

The Commissioner awarded Rs. 4,68,410/- including interest and funeral expenses

1. Whether the Commissioner erred in assessing the deceased’s monthly income at Rs. 4,000/- in the absence of documentary evidence.

2. Whether the Insurance Company is liable to pay interest on the compensation awarded.

3. Whether a driver holding a license to drive a "tractor" is legally authorized to drive a "Light Motor Vehicle" (tempo) with an unladen weight under 7500 kg.

Section 2(21) of the Motor Vehicles (MV) Act, 1988, which defines "Light Motor Vehicle" (LMV) as including transport vehicles, tractors, or motor cars with an unladen weight not exceeding 7500 kg

The Constitution Bench judgment in Bajaj Allianz General Insurance Co. Ltd. v. Rambha Devi (2025) 3 SCC 95, which clarified that an LMV license holder can drive a transport vehicle of the permissible weight category without a separate endorsement

Principle from New India Assurance Co. Ltd. v. Harshadbhai Amrutbhai Modhiya (2006) 2 SCC 417, establishing the insurer's liability for interest under the Workmen's Compensation Act

The Court found that the quantum of income was sufficiently proved as the employer admitted the salary in his testimony, and the Insurance Company failed to cross-examine the claimant on this point

The Court observed that the tempo’s unladen weight was 1180 kg, placing it well within the 7500 kg limit for an LMV under Section 2(21)

Since a "tractor" is expressly included in the definition of LMV and there is no separate license category for tractors under Section 10 of the MV Act, a tractor license is effectively an LMV license

Following Bajaj Allianz and Mukund Dewangan, the Court reasoned that the statutory definition "means" is exhaustive; therefore, an LMV license (including one specified for a tractor) authorizes the holder to drive any vehicle within that weight class, regardless of its description as a transport vehicle

the Insurance Company is liable for interest per settled law

a license to drive a tractor entitles the holder to drive an LMV (tempo) provided the weight is below 7500 kg

The appeal was dismissed, the Commissioner's award was upheld, and the Appellant was directed to disburse the compensation within one month