Registered Owner in Official Records is Liable for Compensation Despite Prior Unregistered Sale of Vehicle.

The appellant, Smt. Shamshida Begam, challenged four awards dated 16/10/2018 passed by the Second Additional Motor Accident Claims Tribunal, Rajnandgaon

The claims arose from a motor accident involving the appellant's vehicle that occurred on 16/09/2016

The appellant contended that she had sold and transferred the offending vehicle to one Thalesh Kumar Sahu on 12/09/2016, supported by a sale deed executed on 26/11/2016 (Ex. D/1C), and therefore should not be liable for compensation

the records indicated that the appellant remained the registered owner on the date of the accident

1. Whether the appellant, as the registered owner of the vehicle on the date of the accident, can be held liable for payment of compensation despite an alleged prior sale of the vehicle.

Section 2(30) of the Motor Vehicles Act, 1988, which defines the "owner" of a vehicle

Naveen Kumar v. Vijay Kumar & Ors. (2018) 3 SCC 1, which established that for the purposes of the Act, the person whose name is reflected in the records of the Registering Authority is the "owner" and is liable to compensate victims

failure to intimate a transfer may result in a fine under Section 50(3) but does not shift liability away from the registered owner in the eyes of the Act

While the appellant claimed a sale occurred on 12/09/2016, the formal transfer deed (Ex. D/1C) was only executed on 26/11/2016, which was over two months after the accident date of 16/09/2016

Following the mandate in Naveen Kumar, the Court reasoned that the statutory definition of "owner" is bound to the official registration records

Since the appellant’s name remained in the Registering Authority’s records on the date of the accident, the legal liability remains with her regardless of any private agreement or delivery of possession to a third party

The appeals were dismissed, and the parties were directed to bear their own costs

The Court affirmed that the mandate of the Motor Vehicles Act regarding the definition of an owner must be strictly fulfilled to ensure claimants receive compensation