Court Emphasizes Liberal Interpretation of Section 166(2) of Motor Vehicles Act, 1988, Directs Tribunal to Decide Compensation Claim on Merits Expeditiously
In a significant judgment delivered on August 24, 2026, the Allahabad High Court (Lucknow Bench) under Justice Syed Qamar Hasan Rizvi, has set aside the dismissal of a motor accident claim petition that was initially rejected on the sole ground of lack of territorial jurisdiction. The claimants, led by Smt. Santosh Singh, had approached the Motor Accident Claims Tribunal, Sitapur, seeking compensation following the death of Rajendra Singh in a road accident involving a car insured with the National Insurance Company Limited.
The Tribunal had dismissed the claim petition filed under Section 166 of the Motor Vehicles Act, 1988, on the ground that the claimants failed to establish their residence within the jurisdiction of Sitapur, and that the accident and defendants were linked to other districts. This dismissal occurred after a full trial and framing of issues, but without a preliminary ruling on jurisdiction.
The High Court found this approach to be hyper-technical and contrary to the benevolent object of the Motor Vehicles Act, which aims to provide just compensation to accident victims or their dependents. The Court emphasized the three-fold option available to claimants under Section 166(2) to file the claim either at the place of accident, where the claimant resides or carries on business, or where the defendant resides or carries on business. The Court noted that the insurance company, a principal defendant in the case, carried on business in Sitapur, which alone conferred jurisdiction on the Tribunal there.
Significantly, the Court allowed the claimants to produce additional evidence under Order XLI Rule 27 of the Code of Civil Procedure, including a school leaving certificate establishing the residence of the claimants in Sitapur. The Court took a compassionate view of the claimants’ inability to produce such evidence earlier due to their limited legal knowledge and the failure of their erstwhile counsel to properly advise them.
Citing Supreme Court precedents such as Mantoo Sarkar v. Oriental Insurance Co. Ltd. and Malati Sardar v. National Insurance Co. Ltd., the Court reiterated that objections to territorial jurisdiction must be raised at the earliest opportunity, and mere technical objections cannot override substantive rights or defeat the remedial purpose of the legislation. The Court also underscored that no prejudice was caused to the respondents, who failed to demonstrate any failure of justice from the claim being filed in Sitapur.
Accordingly, the Court remanded the matter back to the Motor Accident Claims Tribunal, Sitapur, directing it to hear and decide the claim on its merits within four months, ensuring that the claimants receive timely justice. No costs were imposed on either side.
This judgment is a significant reaffirmation of the principle that motor accident claim petitions should be adjudicated liberally and not be defeated on technical grounds, especially when the legislative intent is to provide speedy and adequate compensation to victims and their families.
Bottom Line:
Motor Vehicles Act, 1988 - Territorial jurisdiction of a Claims Tribunal under Section 166(2) must be interpreted liberally to facilitate remedies for accident victims, and a technical objection to jurisdiction cannot override substantive rights or defeat the remedial purpose of the legislation.
Statutory provision(s):
Motor Vehicles Act, 1988 Section 166(2), Civil Procedure Code, 1908 Section 21, Order XLI Rule 27 CPC
Smt. Santosh Singh v. Gajendra Singh, (Allahabad)(Lucknow) : Law Finder Doc Id # 2967741
