Revision against Motor Vehicle award below statutory limit not maintainable merely to settle pending legal issues.

In brief

The question

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

The court held

The court declined to entertain the revisions, holding that the specific criteria for invoking revisional jurisdiction as laid down by the Special Bench were not met.

It also directed

The legal issues regarding Section 150 were left open for determination in other pending litigations.

The Court dismissed the revision petitions but granted the petitioner liberty to seek restoration if the claimants themselves file for enhancement.

01Facts

Shriram General Insurance Company Ltd. challenged three awards passed by the Claims Tribunal, where compensation amounts were fixed at ₹87,100, ₹49,000, and ₹78,450 respectively.

¶ 1

The Insurance Company filed revisions under Section 115 of the CPC, contending that following the 2019 Amendment to the Motor Vehicles Act (MVA), the Tribunal lacked the authority to order "pay and recover" when policy conditions were breached.

¶ 2–3

The petitioner argued that although the quantum was low, the revision was necessary to settle a larger legal question regarding the interpretation of the amended Section 150 of the MVA.

¶ 4

02Issues

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

¶ 6, 8

ii.2. Whether the Insurance Company can invoke revisional jurisdiction solely to settle a question of law when the same issue is already pending before higher courts in other litigations.

¶ 8, 10

03Law Applied

The court primarily applied Section 173(2) of the Motor Vehicles Act, 1988 (as amended in 2019), which bars appeals against awards where the amount in dispute is less than ₹1,00,000.

¶ 5, 9

National Insurance Company v. Shrikant Vinod Tiwari (2007), which held that while a revision under Section 115 CPC is not absolutely barred, it is only maintainable in "特殊 circumstances" such as lack of jurisdiction, failure of justice, or irreparable injury, and cannot be used to circumvent statutory appeal bars.

¶ 6–7

Nirbhai Singh v. Darshan Singh (2025) that parties cannot circumvent statutory prohibitions by invoking supervisory or revisional powers.

¶ 9

Provisions in the judgment · 4 · Linked ones open on LawLens

Code of Civil Procedure, 1908 Section 115

Motor Vehicles Act, 1988 Section 149 Section 150 Section 173

04Reasoning

The court reasoned that while the Special Bench in Shrikant Vinod Tiwari allowed revisions in limited cases to ensure parties are not left remediless, it did not grant liberty to file revisions as a matter of course for awards below the statutory threshold.

¶ 8

Regarding the Insurance Company's plea that a "larger legal interest" regarding Section 150 was involved, the court found this unpersuasive because the same issue is already being litigated in numerous other appeals and before the Supreme Court.

¶ 8, 10

No irreparable injury would occur if these specific low-value awards remained unchallenged.

¶ 10

The litigation costs of pursuing these revisions would likely equal or exceed the actual compensation amounts, rendering the exercise financially counterproductive.

¶ 4, 10

05Holding

The court declined to entertain the revisions, holding that the specific criteria for invoking revisional jurisdiction as laid down by the Special Bench were not met.

¶ 10–11

The legal issues regarding Section 150 were left open for determination in other pending litigations.

¶ 11

The Court dismissed the revision petitions but granted the petitioner liberty to seek restoration if the claimants themselves file for enhancement.

¶ 11–12

LawLens.Madhya Pradesh High Court

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