LMV license holder authorized to drive transport vehicles under 7500 kg without additional specific endorsement.

On 17.03.2007, Shankar Puri (deceased) was struck by a Bolero Camper Jeep (HP-18B-0458) driven by the appellant while it was being reversed at high speed.

The victim suffered spinal fractures and paraplegia, eventually succumbing to his injuries on 29.11.2009.

The Motor Accidents Claims Tribunal (MACT), Nahan, awarded the claimants Rs. 1,05,000 with 7.5% interest.

The Tribunal held that while the vehicle was a "Light Transport Vehicle" (gross weight 2750 kg), the appellant only possessed an LMV (Non-Transport) license.

Consequently, the Tribunal found a breach of insurance terms and ordered the insurer to pay the award but granted it the right to recover the amount from the appellant-owner.

The appellant challenged this finding regarding the validity of his license.

Whether a driver holding a license to drive a Light Motor Vehicle (LMV) is legally authorized to drive a "Light Transport Vehicle" with a gross weight under 7500 kg without a specific transport endorsement.

The Court primarily applied the interpretation of the Motor Vehicles Act, 1988, regarding vehicle classification and licensing.

It relied on the precedent set by the Hon’ble Supreme Court in Bajaj Alliance General Insurance Company Limited vs. Rambha Devi & others (2025) 3 SCC 95, which clarified that a driver holding an LMV license under Section 10(2)(d) is permitted to operate a "transport vehicle" with a gross vehicle weight under 7500 kg without needing additional authorization under Section 10(2)(e).

The Court observed that the offending vehicle's gross weight was 2750 kg, as per the Registration Certificate (Ext. RW-1/C), placing it well within the 7500 kg threshold.

The appellant possessed a valid LMV license at the time of the accident.

Applying the Rambha Devi (supra) principle, the Court reasoned that the core driving skills for LMV and transport vehicles within the specified weight limit are universal.

Therefore, the lack of a specific "transport" endorsement did not render the license invalid or ineffective for the vehicle in question.

The Court found that the Tribunal erred in concluding that the appellant was not authorized to drive the vehicle, as the legal overlap between LMV and light transport categories allows for such operation without additional endorsement.

The appeal was allowed, and the Tribunal's award was modified to exonerate the appellant-owner from liability. The Court directed the Insurance Company (Respondent No. 6) to satisfy the compensation amount in full, setting aside the "pay and recover" liberty previously granted by the Tribunal.