Motor Vehicles Act: Claimant Cannot Invoke Jurisdiction Of A Forum Where Neither Accident Occurred Nor Defendant Resides: Supreme Court

"An interpretation which does not flow from the plain reading of the statutory provisions despite a purposive interpretation cannot be commended. An interpretation that does not find any statutory support cannot be accepted and an interpretation that is in tune with the plain language of the statute ought to be preferred." Supreme Court, in a significant ruling dated September 16, 2026, held that a claim application under Section 166 of the Motor Vehicles Act, 1988, must strictly adhere to the territorial jurisdiction criteria specified in Section 166(2), which does not include the place where the insurer carries on business.

A bench comprising Justice Ujjal Bhuyan and Justice Atul S. Chandurkar observed that while the Act is a piece of beneficial legislation, it cannot be interpreted to allow a claimant to file a petition in a forum that lacks the requisite territorial nexus under the statute.

Strict Construction of Statutory Provisions

The appellant had met with an accident in District Tirupati, Andhra Pradesh, and sought to file a claim in the Motor Accidents Claims Tribunal at Chennai, solely on the ground that the respondent insurance company maintained its head office in that city. The Supreme Court underscored that the Act specifically provides for four options for the claimant, namely, the place where the accident occurred, the place where the claimant resides, the place where the claimant carries on business, or where the defendant resides.

Exclusion of 'Carrying on Business' for Defendants

The court noted that the statute explicitly excludes the place where the defendant 'carries on business' from the criteria for territorial jurisdiction, specifically mentioning only the residence of the defendant. This is a deliberate legislative departure from Section 20 of the Code of Civil Procedure, 1908, which otherwise permits filing a suit where a defendant carries on business. The bench clarified that the term 'defendant' in Section 166(2) refers to the owner or driver of the vehicle, and not the insurer, whose impleadment is optional.

"The place where the defendant carries on business has been specifically omitted while specifying territorial jurisdiction of a Tribunal."

Insurer's Right to Raise Jurisdictional Objections

Addressing the appellant's contention that the insurer could not raise technical jurisdictional objections, the court held that once an insurer is impleaded as a party-respondent, it is entitled to contest the proceedings on all permissible grounds. Relying on the precedent in United India Insurance Co. Ltd. vs. Shila Datta & Others, the bench emphasized that an insurer is not merely a noticee under Section 149(2) when voluntarily impleaded by the claimant and may therefore challenge the territorial competency of the tribunal.

Relevance of the Stage of Objection

The court distinguished the present case from precedents like Mantoo Sarkar and Malati Sardar, where objections regarding jurisdiction were raised at the appellate stage. In those instances, the court was guided by Section 21(1) of the Code of Civil Procedure, requiring the demonstration of a 'failure of justice' to entertain such objections post-award. However, because the objection here was raised at the initial stage, the rigorous requirements of Section 21(1) were not attracted, and the strict mandate of Section 166(2) of the Act applied.

The Supreme Court upheld the Madras High Court’s order, confirming that the Tribunal at Chennai lacked the jurisdiction to entertain the claim. The court directed that the proceedings be transmitted to the Tribunal at Chittoor, the location where the claimant resides and where the defendant is situated. This ensures that the litigation proceeds before a forum that possesses clear, statutory territorial authority under the Motor Vehicles Act.

Date of Decision: 16 September 2026