### Revision Not Maintainable Against Low-Quantum Awards Solely to Resolve Substantive Legal Issues Already Pending Before Higher Courts

The Petitioner, an insurance company, filed a revision petition under Section 115 of the Code of Civil Procedure (CPC) challenging an award of ₹15,000 passed by the Motor Accident Claims Tribunal.

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

The Petitioner contended that following the 2019 Amendment to the Motor Vehicles Act (specifically the renumbering and modification of Section 149 to Section 150), the "pay and recover" provision no longer exists, and liability should fall solely on the owner.

1. Whether a revision petition under Section 115 CPC is maintainable against a Claims Tribunal award where the amount in dispute is less than ₹1,00,000, in light of the statutory bar on appeals under Section 173(2) of the Motor Vehicles Act.

2. Whether the Insurance Company can invoke revisional jurisdiction to settle a question of law (interpretation of Section 150) in a case involving a negligible compensation amount.

The court relied on Section 173(2) of the Motor Vehicles Act, 1988 (as amended in 2019), which prohibits appeals if the amount in dispute is less than ₹1,00,000.

It applied the precedent from the Five-Judge Special Bench 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 court also noted recent Jurisprudence from the Punjab and Haryana High Court in Nirbhai Singh v. Darshan Singh (2025), which deprecated circumventing statutory appeal bars via Article 227 or revision petitions.

The court observed that the Petitioner sought to challenge a very low quantum (₹15,000) under the guise of an "issue of larger importance" regarding the interpretation of the amended Section 150.

However, the court reasoned that since the same legal issue is already pending in numerous other appeals before various High Courts and the Supreme Court, the legal standing of the insurer would not be irreversibly prejudiced if this specific low-value award went unchallenged.

Applying the Shrikant Vinod Tiwari criteria, the court found no "irreparable injury" or "failure of justice" because the litigation costs for both parties would likely exceed the compensation amount itself.

The court emphasized that revisional jurisdiction should not be used as a routine substitute for an appeal specifically barred by the legislature.

It held that the statutory mandate barring challenges to awards under ₹1.00 Lakh must be respected unless exceptional circumstances exist, which were absent here given the pending litigation on the same legal point elsewhere.

The court left the legal issues regarding Section 150 open and granted the Petitioner the right to seek restoration of the revision only if the respondent-claimant files for enhancement of the award.