Revision against sub-lakh motor accident awards lies only in exceptional jurisdictional or irreparable-injury cases.

The Insurance Company filed a revision under Section 115 of the Code of Civil Procedure, 1908, challenging an award of the Claims Tribunal granting compensation of ₹77,932 to the claimant-respondent.

Although the Tribunal found a breach of the insurance-policy conditions, it directed the Insurance Company to satisfy the award with liberty to recover the amount from the vehicle owner.

The Insurance Company acknowledged that the amount involved was below the statutory appellate threshold of ₹1 lakh, but argued that the revision raised an issue of larger legal importance.

1. Whether a civil revision under Section 115 CPC is maintainable against a Claims Tribunal award where the amount in dispute is below the ₹1 lakh threshold prescribed under Section 173(2) of the Motor Vehicles Act, 1988.

2. Whether the Insurance Company could invoke revisional jurisdiction to challenge the Tribunal’s direction of “pay and recover” on the basis of the alleged effect of the 2019 amendment to Sections 149 and 150 of the Motor Vehicles Act.

3. Whether the present case disclosed the exceptional circumstances—such as want or excess of jurisdiction, failure of justice, or irreparable injury—in which revision may nevertheless lie despite the statutory bar on appeal.

Section 173(2) of the Motor Vehicles Act, 1988 bars an appeal against a Claims Tribunal award where the amount in dispute is less than ₹1 lakh, following the amendment that substituted “one lakh” for “ten thousand” rupees.

Section 115 CPC confers limited revisional jurisdiction and does not permit routine reappraisal of a Tribunal’s award.

In National Insurance Company v. Shrikant Vinod Tiwari, 2007 (2) J.L.J. 138, the Special Bench held that revision may lie in exceptional cases where the award is without or in excess of jurisdiction, would occasion failure of justice or irreparable injury, or involves circumstances such as absence of an insurance policy or compensation awarded despite a finding that the injury was unrelated to the motor vehicle.

The Court also relied on Nirbhai Singh v. Darshan Singh, 2025 SCC OnLine P&H 12450, and the principle that a party cannot ordinarily circumvent a statutory bar on appeal by invoking revisional or supervisory jurisdiction.

The Court accepted that the revision raised a potentially important question concerning the interpretation of amended Section 150 and the permissibility of “pay and recover” orders.

However, the award was only for ₹77,932, and therefore an appeal was barred by Section 173(2) of the Motor Vehicles Act.

Although the Special Bench decision recognised limited circumstances in which revision could be entertained despite the appellate bar, the present challenge did not involve want or excess of jurisdiction, fraud, false implication, or any comparable failure of justice or irreparable injury.

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

The Court also considered that the litigation costs would likely equal or exceed the compensation amount and that permitting such a revision would effectively allow the Insurance Company to use revision as a substitute for an appeal barred by statute.

It declined to decide the substantive issue regarding the amended Section 150 and the validity of the “pay and recover” direction, leaving that question open for determination in other pending proceedings.

Admission was declined and the civil revision was dismissed.

The Court clarified that, if the claimant subsequently files a case seeking enhancement of compensation, the Insurance Company would be entitled to seek revival of the revision.