Revisional jurisdiction cannot be invoked to circumvent statutory bars on appeals for motor vehicle awards below one lakh rupees.

The Petitioner, an Insurance Company, filed two civil revisions under Section 115 of the Code of Civil Procedure (CPC) challenging awards passed by the Motor Accidents Claims Tribunal.

In CR No. 11/2026, the compensation was ₹26,525, and in CR No. 09/2026, it was ₹80,162.

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

The Petitioner argued that following the 2019 Amendment to the Motor Vehicles Act (MVA), the provision corresponding to Section 149(4) was omitted from the renumbered Section 150, thereby stripping the Tribunal of the power to order "pay and recover".

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

2. Whether the "pay and recover" direction remains legally permissible after the 2019 Amendment to the Motor Vehicles Act.

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 ₹1,00,000.

The Special Bench decision in National Insurance Company v. Shrikant Vinod Tiwari and others (2007 (2) J.L.J. 138), which held that while a revision under Section 115 CPC is not strictly barred, it is maintainable only in limited, exceptional circumstances such as lack of jurisdiction, failure of justice, or irreparable injury.

The principle from Nirbhai Singh v. Darshan Singh (2025 SCC OnLine P & H 12450), stating that parties cannot circumvent statutory bars on appeals by invoking the high court's revisional or supervisory jurisdiction.

The Court observed that the legislature intentionally raised the threshold for appeals from ₹10,000 to ₹1,00,000 to limit litigation over small amounts.

While the Petitioner argued that the legal interpretation of the amended Section 150 was of "larger importance," the Court found that this specific legal question is already pending in numerous other litigations before various High Courts and the Supreme Court.

Consequently, there was no risk of a final settlement of law against the insurer if these specific revisions were not entertained.

Furthermore, the Court noted that the litigation costs for these revisions would likely exceed the compensation amounts (₹26,525 and ₹80,162), thus failing to meet the criteria of "irreparable injury" or "failure of justice" established by the Special Bench in Shrikant Vinod Tiwari.

The petitions were dismissed, but liberty was granted to the Petitioner to seek restoration of these revisions if the claimants were to file for enhancement of the awards.