Revision against MACT awards below statutory appeal threshold requires exceptional grounds of jurisdictional error or manifest injustice.

The New India Assurance Company (Petitioner) challenged an award passed by the Claims Tribunal, which granted compensation of ₹64,500 to the claimant (Respondent No. 1) for injuries sustained while traveling in a car that turned turtle.

The Petitioner contended that the insurance policy did not cover passengers in the car; however, the Tribunal found the Petitioner failed to prove this exclusion through evidence.

The Petitioner filed this revision under Section 115 of the CPC, arguing the issue was of "larger importance" despite the low quantum of the award.

1. Whether a revision under Section 115 of the CPC is maintainable against a Claims Tribunal award where the amount in dispute is less than ₹1,00,000, given the statutory bar on appeals under Section 173(2) of the Motor Vehicles Act?

2. Whether the Petitioner demonstrated "special circumstances," such as failure of justice or irreparable injury, to justify the exercise of revisional jurisdiction in a low-quantum case?

Section 173(2) of the Motor Vehicles Act, 1988, which bars appeals against awards where the amount in dispute is less than ₹1,00,000.

The five-judge Special Bench decision in National Insurance Company v. Shrikant Vinod Tiwari (2007), which established that while an appeal may be barred, a revision under Section 115 CPC lies only on limited grounds such as lack of jurisdiction, failure of justice, or irreparable injury.

Nirbhai Singh v. Darshan Singh (2025), which deprecated the practice of using Article 227 or revisions to circumvent statutory prohibitions on appeals.

The court reasoned that the legislature intentionally raised the threshold for appeals to ₹1,00,000 to limit litigation over small amounts.

Applying the Shrikant Vinod Tiwari criteria, the court found that a revision cannot be filed as a "matter of course" or in a "routine matter".

The court observed that the Petitioner failed to show any "failure of justice," fraud, or jurisdictional error.

It further noted that the litigation expenses for both parties in this revision would likely equal or exceed the awarded amount of ₹64,500, making the challenge economically counter-productive and a burden on the judicial system.

Consequently, the court determined that no legal question of larger importance was involved to override the statutory bar.

The Revision was dismissed.

However, the court granted the Petitioner liberty to seek restoration of the revision should the claimant file a cross-case for enhancement of the compensation quantum.