Kerala High Court directs Motor Accident Tribunals to number claims even without Aadhaar or PAN details at filing stage

The petitioner filed a claim petition under Section 166 of the Motor Vehicles Act, 1988, before the Motor Accidents Claims Tribunal, Palakkad, seeking compensation for injuries sustained in a motor accident dated 13 November 2025.

The petition was presented on 31 March 2026. Although the petitioner stated in the list of documents that his Aadhaar and PAN Cards would be produced at the time of evidence, the Tribunal returned the petition on 24 April 2026 for non-production of copies of those documents.

The petition was repeatedly resubmitted with requests for time to cure the defect but was returned on the same ground.

The petitioner therefore invoked the High Court’s jurisdiction under Article 227 of the Constitution, seeking numbering of the claim petition and permission to produce the documents before the pre-trial stage.

During the proceedings, the Tribunal reported that the claim petition had subsequently been numbered as OP(MV) No. 2025 of 2026 and posted for return of notice.

Whether the Motor Accidents Claims Tribunal could refuse to number a claim petition merely because the petitioner’s Aadhaar and PAN details or copies were not furnished at the time of filing.

Whether the petitioner was entitled to a direction under Article 227 of the Constitution for numbering of the claim petition and for furnishing the required identity particulars within a reasonable time.

The Court applied Section 166 of the Motor Vehicles Act, 1988, governing claims for compensation arising from motor accidents, together with the Kerala Motor Vehicles Rules, 1989, concerning the particulars required in claim petitions.

It also applied Kerala High Court Circular No. 1/2025 dated 19 September 2025, issued pursuant to directions of the Supreme Court, which requires Aadhaar number, PAN details and e-mail ID, if any, of claimants to be incorporated in claim petitions.

Crucially, Clause 1(c) of the Circular mandates that the Tribunal shall register and number the claim petition even when those particulars are not furnished at the time of filing; under Clause 1(d), notice may be issued subject to furnishing the details within a reasonable time, and no interim award or order may be made until compliance.

The Court exercised supervisory jurisdiction under Article 227 to ensure adherence to this procedure.

The Court held that the Tribunal’s initial refusal to number the petition was inconsistent with Clause 1(c) of Circular No. 1/2025.

While the Circular requires Aadhaar, PAN and e-mail particulars to be furnished, it expressly distinguishes between the obligation to provide those details and the Tribunal’s duty to register and number the claim petition.

Therefore, non-production of the documents at the filing stage could justify directing the claimant to furnish them within a specified period and withholding issuance of notice until compliance, but it could not justify indefinite withholding of numbering.

Since the Tribunal ultimately reported that the petition had been numbered as OP(MV) No. 2025 of 2026 and posted for return of notice, the relief sought had effectively been granted.

The petition may be numbered, while notice and interim relief remain subject to subsequent compliance with the Circular.

As the Tribunal had already numbered the petitioner’s claim petition, the High Court found that no further orders were necessary and disposed of the Original Petition.