Motor Vehicles Amendment, limitation of six months for filing claims does not impose embargo on condonation of delay

Karnataka High Court Upholds Condonation of Delay in Motor Accident Claims. Court emphasizes the beneficial nature of the Motor Vehicles Act and allows delays to be condoned for justice to prevail.

In a significant ruling, the Karnataka High Court, Kalaburagi Bench, has upheld the condonation of delays in filing motor accident compensation claims, highlighting the beneficial nature of the Motor Vehicles Act, 1988. The judgment was delivered by Justice Shivashankar Amarannavar on August 13, 2025, in a series of writ petitions filed by M/s Sriram General Insurance Co. Ltd. against respondents Anil and others.

The central issue in these petitions was the applicability of a six-month limitation period introduced by an amendment to Section 166(3) of the Motor Vehicles Act, effective from April 1, 2022, which mandates that claims for compensation must be filed within six months of the accident. The petitioners sought the rejection of claims filed beyond this period, arguing that the amendment precluded any condonation of delay.

The Court, however, took a different stance, emphasizing that the Motor Vehicles Act is a beneficial legislation designed to aid victims of road accidents. It ruled that the provisions of the Limitation Act, 1963, particularly Section 5, which allows for condonation of delay if sufficient cause is shown, are applicable to proceedings under the Motor Vehicles Act. The Court observed that a blanket embargo on condonation would be contrary to the Act's intent.

The judgment also criticized procedural lapses by investigating officers, particularly the failure to submit Detailed Accident Reports (DAR) within the prescribed 90 days, which could disadvantage claimants. The Court stated that such procedural delays by authorities should not be used by insurance companies to deny compensation on technical grounds.

Furthermore, the Court reiterated the necessity for investigating officers to adhere to Sections 159 and 160 of the Motor Vehicles Act, which require them to submit accident reports to the Claims Tribunal promptly. The Court underscored that the DAR could be treated as a claim petition under Section 166(4) of the Act, expediting the compensation process without burdening claimants with procedural technicalities.

The ruling aligns with precedents set by other High Courts and the Supreme Court of India, which have consistently interpreted the Motor Vehicles Act in a manner that supports the rights of accident victims to seek compensation without undue procedural hurdles.

This judgment reaffirms the judiciary's commitment to ensuring that the Motor Vehicles Act serves its intended purpose of providing timely and effective relief to accident victims, and it sends a strong message against the misuse of procedural technicalities to deny rightful claims.

Bottom Line:

Motor Vehicles Act, 1988 - Beneficial provision under Section 166(3) - Amendment introducing limitation period of six months for filing compensation claims does not impose a blanket embargo on condonation of delay - Application of Section 5 of the Limitation Act permissible to condone delays if sufficient cause is shown - Police failure to submit Detailed Accident Report (DAR) under Section 159 and 160 of the MV Act cannot disadvantage claimants.

Statutory provision(s): Motor Vehicles Act, 1988 Sections 166, 159, 160, 161; Limitation Act, 1963 Section 5.

M/s Sriram General Insurance Co. Ltd. v. Anil, (Karnataka)(Kalaburagi Bench) : Law Finder Doc Id # 2768155