Revisions against motor accident awards below statutory appeal thresholds are not maintainable merely to settle general legal questions.

The Petitioner (Insurance Company) filed a civil revision under Section 115 of the CPC challenging a Claims Tribunal award of ₹15,000.

The Tribunal found the vehicle was 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 (specifically the renumbering of Section 149 to Section 150), the "pay and recover" provision was deleted, and liability should rest solely on the vehicle owner.

The court noted that the awarded amount was significantly below the ₹1.00 Lakh threshold for appeals.

1. Whether a revision petition under Section 115 CPC is maintainable against a Motor Vehicles Act award where the amount in dispute is less than ₹1,00,000, thereby barring a statutory appeal under Section 173(2).

2. Whether the Insurance Company can invoke revisional jurisdiction solely to settle a legal question regarding the interpretation of Section 150 of the amended Motor Vehicles Act when the financial quantum of the award is negligible.

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

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

It further noted the principle from Nirbhai Singh v. Darshan Singh (2025) that parties cannot circumvent statutory appeal bars by invoking supervisory or revisional jurisdictions.

The court reasoned that although a Special Bench previously allowed revisions for low-quantum awards to prevent parties from being remediless, such petitions must not be filed as a "matter of course".

In this instance, the Petitioner failed to demonstrate "irreparable injury" or "failure of justice".

The court found that the legal issue regarding the interpretation of Section 150 is already pending in numerous other high-stakes appeals before various High Courts and the Supreme Court; thus, leaving this specific small award unchallenged would not prejudice the insurer's legal position.

Furthermore, the court observed that the litigation costs of pursuing the revision would likely exceed the actual award of ₹15,000, making the exercise economically redundant and a burden on judicial resources.

The petition was dismissed, though the court reserved the Petitioner's right to seek restoration should the claimant file for enhancement.

The legal question regarding the "pay and recover" principle under the amended Section 150 was left open for determination in more appropriate, pending proceedings.