Revision against sub-₹1 lakh motor accident awards is impermissible absent exceptional jurisdictional or irreparable injustice.

The Insurance Company filed a revision under Section 115 of the Code of Civil Procedure challenging an award of the Claims Tribunal granting compensation of ₹6,000 to the claimant.

Although the Tribunal found that the offending vehicle was being operated in breach of the insurance-policy conditions, it directed the Insurance Company to pay the compensation first and recover it from the owner.

The Insurance Company contended that, after the 2019 amendment to the Motor Vehicles Act, Section 149 had been renumbered as Section 150 and the provision corresponding to Section 149(4) had been omitted; consequently, the Tribunal could not order “pay and recover”.

The Insurance Company acknowledged that the award was below the statutory appellate threshold but argued that the revision raised an important legal issue concerning the amended Section 150.

Whether a revision under Section 115 CPC is maintainable against a Claims Tribunal award below the monetary threshold prescribed under Section 173(2) of the Motor Vehicles Act.

Whether the Insurance Company could invoke revisional jurisdiction to challenge the Tribunal’s direction to “pay and recover” on the ground that the 2019 amendment altered the statutory basis for such a direction.

Whether the present case involved exceptional circumstances—such as lack or excess of jurisdiction, failure of justice, or irreparable injury—warranting exercise of revisional jurisdiction despite the low quantum of the award.

Section 173(2) of the Motor Vehicles Act bars an appeal against a Claims Tribunal award where the amount in dispute is less than ₹1 lakh, following the amendment enhancing the earlier threshold of ₹10,000.

Section 115 CPC confers limited revisional jurisdiction and does not permit routine reconsideration of an award.

Relying on the five-Judge Special Bench decision in National Insurance Company Ltd. v. Shrikant Vinod Tiwari, 2007 (2) JLJ 138, the Court held that revision may exceptionally lie where the Tribunal acted without or in excess of jurisdiction, the award would cause failure of justice or irreparable injury, the insurance policy was not issued by the insurer, compensation was awarded despite absence of a causal connection with the motor vehicle, or the owner was improperly saddled with liability.

The statutory bar on appeal cannot ordinarily be circumvented by invoking revisional or supervisory jurisdiction; the Court also relied on Nirbhai Singh v. Darshan Singh, 2025 SCC OnLine P&H 12450, concerning the impermissibility of bypassing the appellate restriction.

The Court accepted that the revision raised a potentially important question concerning the effect of the 2019 amendment and the continuance of “pay and recover.” However, the award was only ₹6,000, substantially below the ₹1 lakh threshold under Section 173(2), and the revision did not fall within the exceptional categories identified in National Insurance Company Ltd.

The legal issue was already pending in several matters before the High Court, other High Courts, and the Supreme Court; therefore, refusal to entertain this particular revision would not cause irreparable injury or prevent adjudication of the issue.

The Court further considered that the litigation expenses could equal or exceed the compensation awarded and that entertaining the revision would effectively permit the Insurance Company to use revision as a substitute for the statutorily barred appeal.

Admission was declined and the revision was dismissed because no exceptional circumstance justifying revisional interference was established.

The Insurance Company was granted liberty to seek restoration of the revision if the claimant subsequently filed proceedings seeking enhancement of compensation.