Revision cannot routinely circumvent the statutory bar on appeals against awards below ₹1 lakh.

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 ₹33,783 to respondent No. 1.

The Insurance Company contended that, following the 2019 amendment to the Motor Vehicles Act, 1988, Section 149 had been renumbered as Section 150 and the provision corresponding to Section 149(4), which had supported a “pay and recover” direction, was omitted.

The Court noted that Section 173(2) of the Motor Vehicles Act bars an appeal where the amount in dispute is below ₹1,00,000, whereas the award in the present case was only ₹33,783.

The Insurance Company nevertheless urged that the revision be entertained because it raised an issue of wider legal importance concerning the interpretation of amended Section 150.

1. Whether a revision under Section 115 CPC is maintainable against a Claims Tribunal award below ₹1,00,000, notwithstanding the statutory bar on appeals under Section 173(2) of the Motor Vehicles Act?

2. Whether the present revision involved such exceptional circumstances—such as want or excess of jurisdiction, failure of justice, or irreparable injury—as would justify exercising revisional jurisdiction?

3. Whether the Insurance Company’s challenge to the Tribunal’s “pay and recover” direction, based on the alleged effect of the 2019 amendment and the renumbering of Section 149 as Section 150, warranted adjudication in the present revision?

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 ₹1,00,000; the statutory threshold had been enhanced from ₹10,000 by amendment.

Section 115 CPC confers limited revisional jurisdiction, which may be exercised where the Tribunal has acted without jurisdiction, exceeded its jurisdiction, or where its order, if allowed to stand, would occasion failure of justice or irreparable injury.

In National Insurance Company v. Shrikant Vinod Tiwari, 2007 (2) J.L.J. 138, a five-Judge Special Bench held that a revision may, in exceptional circumstances, lie against a Claims Tribunal award despite the bar on appeal, but not as a matter of routine or as a substitute for the barred statutory appeal.

The Court also considered 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.

Although the Insurance Company raised a potentially significant question concerning the amended statutory scheme and the permissibility of “pay and recover” directions, the Court held that the existence of a legal question alone did not justify entertaining a revision against an award of ₹33,783.

The issue was already pending consideration in several other matters before the High Court, other High Courts, and the Supreme Court; consequently, dismissal of the present revision would not cause the Insurance Company irreparable prejudice or prevent the legal issue from being authoritatively decided elsewhere.

The case also did not involve fraud, false implication, absence of an insurance policy, an award without jurisdiction, or any comparable circumstance contemplated by the Special Bench in Shrikant Vinod Tiwari.

Given that the litigation costs would likely equal or exceed the compensation awarded, and would impose additional costs on the respondents, the Court declined to exercise its limited revisional jurisdiction.

The Insurance Company’s revision was therefore not entertained; admission was declined and the revision was dismissed, leaving the legal questions concerning amended Section 150 and “pay and recover” directions open for determination in other pending cases.

The Court directed that, if the claimant subsequently filed proceedings for enhancement of compensation, the Insurance Company would have the right to seek restoration of the revision.