Revision cannot circumvent statutory bars on motor accident appeals absent jurisdictional error or manifest injustice.

The petitioner Insurance Company challenged an award passed by the Motor Accident Claims Tribunal (MACT) granting ₹15,000 in compensation to the claimant-respondent

The Insurance Company contended that the vehicle was falsely implicated and that the driver of the car, rather than the insured truck, was negligent

The Court raised a preliminary objection regarding the maintainability of the revision, noting that the compensation amount was significantly below the statutory threshold for appeals and that the litigation costs would likely exceed the awarded amount

1. Whether a revision petition under Section 115 of the CPC is maintainable against a Claims Tribunal award where the disputed amount is less than the ₹1,00,000 threshold prescribed for appeals under Section 173(2) of the Motor Vehicles Act

2. Whether the present case falls within the exceptional circumstances that permit the exercise of revisional jurisdiction despite the statutory bar on appeals for low-quantum awards

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

It relied on the Special Bench decision in National Insurance Co. v. Shrikant Vinod Tiwari (2007), which established that while an appeal may be barred, a revision under Section 115 CPC remains available on strictly limited grounds, such as excess of jurisdiction, failure of justice, or cases where no insurance policy was issued

The Court also noted the restrictive approach taken in Nirbhai Singh v. Darshan Singh (2025) by the Punjab and Haryana High Court, which deprecated the use of revisional jurisdiction to circumvent statutory bars on appeals

The Court observed that although the Special Bench in Shrikant Vinod Tiwari allowed for revisions, it emphasized they should not be filed as a "matter of course" or for routine matters

In the present case, the Insurance Company failed to demonstrate any jurisdictional error, fraud, or irreparable injury that would justify a revision

The Court noted that the grounds raised (negligence and false implication) were standard factual disputes rather than larger legal issues of public importance

Furthermore, the Court reasoned that entertaining a revision for a ₹15,000 award—where litigation expenses for both parties would surpass the compensation itself—would not serve the interests of justice

It concluded that the case did not meet the "failure of justice" or "irreversible injury" criteria required to bypass the legislative intent of Section 173(2)

The revision was dismissed solely on the ground of maintainability

However, the Court clarified that this dismissal would not prejudice the Insurance Company’s rights in a related pending appeal (MA No. 5713 of 2023) arising from the same accident involving a death claim, leaving those legal issues open