N-1 category vehicles manufactured for goods carriage must be registered as transport vehicles.

The respondent purchased a Mahindra Bolero Camper 4WD PSD, which the manufacturer categorized as an ‘N1’ goods vehicle.

The respondent sought to register it as a "non-transport" light motor vehicle, claiming he only used it to transport livestock and agricultural materials for personal use on his farm.

A Single Judge of the High Court, via order dated 28.11.2025, directed the Appellant (RTO) to consider the respondent's application for non-transport registration.

The RTO appealed this direction, contending that the vehicle's inherent design and classification by the manufacturer necessitate its registration as a transport vehicle.

1. Whether a vehicle categorized by the manufacturer as 'N-1' for the carriage of goods can be registered as a non-transport vehicle based on the owner's personal use.

2. Whether the Court can sustain a direction to register a vehicle contrary to its statutory classification under the Motor Vehicles Act and Rules.

Rule 2(p) of the Central Motor Vehicles Rules, which defines 'N-1' category vehicles as motor vehicles used for the carriage of goods with a gross weight not exceeding 3.5 tonnes.

Section 2(47) of the Motor Vehicles Act, 1988, which defines a "transport vehicle" to include a public service vehicle and a goods carriage.

The legal principle established is that categorization depends on the nature of the vehicle, the purpose of manufacture, and the manufacturer’s certification, rather than the subjective intent of the owner.

The Court reasoned that the classification of a vehicle is objective and governed by the manufacturing specifications provided by Mahindra and Mahindra, who designated the Bolero Camper as an 'N1' vehicle.

By reading Section 2(47) of the Act and Rule 2(p) of the Rules in conjunction, the Court found that any vehicle designed for the carriage of goods is legally a "transport vehicle".

The Court dismissed the respondent’s argument regarding personal agricultural use, stating that the presence of a facility to carry goods automatically classifies it as a transport vehicle regardless of whether the goods are for personal or commercial use.

The Court further noted that any documents suggesting otherwise were "self-serving" and that registration as a non-transport vehicle cannot be compelled by a court if it violates the statutory framework.

It held that the respondent's vehicle must be registered as a "transport vehicle" because its manufacturing category (N-1) and design for carrying goods dictate its legal status.

The Court issued a specific direction to the Appellant to register the vehicle as a transport vehicle.