Revision under Section 115 CPC cannot circumvent the statutory bar on appeals for MACT awards below one lakh rupees.

The New India Insurance Company (petitioner) filed a civil revision challenging an award passed by the Motor Accident Claims Tribunal, which granted compensation of ₹62,505 to the claimant-respondent

The petitioner contested the Tribunal’s "pay and recover" direction, arguing that following the 2019 Amendment to the Motor Vehicles Act, Section 150 (formerly Section 149) no longer contains provisions corresponding to the old Section 149(4) that permitted such directions in cases of policy breach

Because the awarded amount was below the ₹1,00,000 threshold required to file a statutory appeal under Section 173(2) of the Act, the petitioner invoked the revisional jurisdiction of the High Court under Section 115 of the CPC

Section 173(2) of the Motor Vehicles Act, 1988 (as amended in 2019), which prohibits appeals against awards where the amount in dispute is less than ₹1,00,000

Special Bench (five-judge) precedent in National Insurance Company v. Shrikant Vinod Tiwari and others (2007), which established that while a revision under Section 115 CPC is not absolutely barred, it is restricted to limited grounds such as jurisdictional error, failure of justice, or irreparable injury

Nirbhai Singh v. Darshan Singh (2025), which held that parties cannot circumvent statutory prohibitions on appeals by invoking revisional or supervisory jurisdictions

The court reasoned that while the Special Bench in Shrikant Vinod Tiwari recognized the maintainability of revisions in exceptional circumstances, it did not permit them as a matter of course to bypass legislative bars on appeals

The court found that the petitioner’s justification—the need to interpret the amended Section 150—was insufficient because that specific legal question is already under adjudication in numerous other pending cases before various High Courts and the Supreme Court

Therefore, leaving this small-value award unchallenged would not cause irreparable injury or settle the law against the insurer

Additionally, the court noted that the litigation expenses for this revision would likely equal or exceed the awarded amount of ₹62,505, rendering the pursuit of the revision commercially and legally illogical

The court dismissed the revision and declined to entertain the challenge

The court left the legal issues regarding Section 150 open for determination in other pending matters but granted the petitioner liberty to restore this revision if the claimant seeks an enhancement of the compensation