Revision does not lie against awards below statutory limit purely for settling pending legal issues.

The Petitioner Insurance Company filed a civil revision under Section 115 of the CPC challenging a Claims Tribunal award of ₹72,308/-.

The Tribunal found the vehicle was operated in breach of policy conditions but applied the "pay and recover" principle.

The Petitioner argued that following the 2019 Amendment to the Motor Vehicles Act (MVA), Section 149 was renumbered as Section 150, and the provision enabling "pay and recover" was omitted.

The appeal was filed as a revision because Section 173(2) of the MVA bars statutory appeals for awards below ₹1,00,000/-.

1. Whether a revision under Section 115 CPC is maintainable against a Motor Accident Claims Tribunal award where a statutory appeal is barred by the threshold limit under Section 173(2) of the MVA.

2. Whether the Insurance Company can invoke revisional jurisdiction solely to settle a question of law (interpretation of Section 150) despite the low quantum of the award.

Section 173(2) of the Motor Vehicles Act, 1988 (as amended in 2019), which bars appeals for disputes below ₹1,00,000/-.

The Five-Judge Special Bench precedent in National Insurance Company v. Shrikant Vinod Tiwari (2007), which held that while a revision under Section 115 CPC is not absolutely barred, it is limited to cases of jurisdictional error, failure of justice, or irreparable injury.

The principle from Nirbhai Singh v. Darshan Singh (2025), stating that parties cannot circumvent statutory appeal bars by invoking supervisory or revisional jurisdictions.

The Court observed that while the Special Bench in Shrikant Vinod Tiwari allows revisions in exceptional circumstances, the current petition did not meet those criteria.

Although the Petitioner raised a significant legal issue regarding the 2019 Amendment, the Court found that this specific issue is already pending in numerous other appeals before various High Courts and the Supreme Court.

Consequently, leaving this specific low-quantum award unchallenged would not cause "irreparable injury" or a "failure of justice" as defined by the Special Bench.

The Court further noted that the litigation costs for this revision would likely exceed the actual award amount, making the exercise economically unviable and an improper use of judicial machinery to bypass the legislative intent of Section 173(2).

The revision was dismissed, with liberty to restore only if the claimants cross-appeal for enhancement.