Revision of low-value motor accident awards for interpreting amended Section 150 is barred absent irreparable injury.

The applicant Insurance Company challenged an award passed by the Claims Tribunal, which granted compensation of ₹19,650/- to the respondent

Although the Motor Vehicles (Amendment) Act, 2019, increased the threshold for filing appeals under Section 173(2) to ₹1,00,000/-, the applicant filed a civil revision under Section 115 of the CPC

The applicant contended that since the 2019 Amendment renumbered Section 149 as Section 150 and omitted provisions corresponding to Section 149(4), the Tribunal erred in applying the "pay and recover" principle after finding a breach of policy conditions

Section 173(2) of the Motor Vehicles Act, 1988 (as amended in 2019), which bars appeals against awards where the amount in dispute is less than ₹1.00 Lakh

The five-judge Special Bench decision in National Insurance Co. v. Shrikant Vinod Tiwari, 2007 (2) J.L.J. 138, which held that while a revision under Section 115 CPC is not barred, it lies only in "special circumstances" such as lack of jurisdiction, failure of justice, or irreparable injury, and not in routine matters

Nirbhai Singh v. Darshan Singh, 2025 SCC OnLine P & H 12450, which deprecated the practice of using Article 227 or revisions to circumvent the statutory bar on appeals

The Court observed that the legislature intentionally raised the appeal threshold to ₹1.00 Lakh to prevent trivial litigation

While the applicant raised a legal issue regarding the interpretation of the amended Section 150, the Court noted that this issue is already sub-judice in numerous other appeals before various High Courts and the Supreme Court

Consequently, the present award would not result in "irreparable loss" or a final settlement of law against the Company if left unchallenged

The Court further reasoned that the litigation costs for both parties would likely exceed the awarded amount of ₹19,650/-, making the revision a commercially and legally disproportionate remedy

The Court found that the applicant failed to meet the "special circumstances" criteria established in Shrikant Vinod Tiwari

The Court declined to entertain the revision and dismissed it

However, the Court granted the Insurance Company the right to restore this revision if the claimant seeks enhancement and clarified that this order does not prejudice the Company's right to argue the same legal issues in other pending appeals exceeding the ₹1.00 Lakh threshold