M/S. BAJAJ ALLIANCE GENERAL INSURANCE CO. LTD. vs RAMBHA DEVI, 2024
Case Title and Citation: M/S. BAJAJ ALLIANCE GENERAL INSURANCE CO. LTD. V. RAMBHA DEVI 2024 INSC 840 (6 November 2024)
Factual Background
The Motor Vehicles Act, 1988 (MV Act) originally classified vehicles based on weight categories, where light vehicles weighed less than 7,500 kgs. Following a 1994 amendment, the Act replaced the categories of medium and heavy motor vehicles with the class of ‘Transport Vehicles’. This change led to legal uncertainty regarding whether an individual holding a license specifically for a “Light Motor Vehicle” (LMV) could legally drive a ‘Transport Vehicle’ (used to transport goods or passengers) that weighed less than 7,500 kgs. Insurance companies routinely contested claims when drivers with LMV licenses were operating these light ‘Transport Vehicles’. In 2017, a three-judge bench, in the case of Mukund Dewangan, ruled that an LMV license holder could drive a light transport vehicle (under 7,500 kgs). However, this ruling was challenged by insurance companies, and subsequent Benches of the Supreme Court referred the matter for reconsideration by a larger bench, noting that Mukund Dewangan had allegedly overlooked several important provisions of the MV Act and Rules. The matter was thus placed before a five-judge Constitution Bench.
Issue(s)
- Whether an individual holding a license for a ‘Light Motor Vehicle’ (LMV) is legally permitted to operate a ‘Transport Vehicle’ if its gross vehicle weight does not exceed 7,500 kgs, without requiring a specific separate endorsement for the ‘Transport Vehicle’ class.
- Whether the specific additional requirements outlined for ‘transport vehicles’ in the MV Act (such as age limits, medical certificates, and extended training periods) must also be applied to ‘Transport Vehicles’ that fall within the ‘Light Motor Vehicle’ weight category (i.e., under 7,500 kgs).
- Whether the decision rendered in Mukund Dewangan v. Oriental Insurance Company Limited (2017) should be held per incuriam for failing to consider several key statutory provisions of the MV Act and Rules.
Decision of the Supreme Court
The Constitution Bench, composed of five judges, unanimously upheld the previous judgment in Mukund Dewangan. The Court ruled that an individual possessing a license for a ‘Light Motor Vehicle’ (LMV) is legally entitled to drive a transport vehicle as long as the gross vehicle weight of that vehicle is less than 7,500 kgs, and no additional endorsement is required on their license.
Reason for the Decision
The Court’s reasoning was based on a harmonious construction of the MV Act, prioritizing legislative intent and practical outcomes:
- Harmonious Interpretation of Definitions: The definition of “Light Motor Vehicle” in Section 2(21) of the MV Act explicitly uses the word “means” a transport vehicle, omnibus, motor car, etc., provided the weight does not exceed 7,500 kgs. The use of the word “means” suggests a strict and exhaustive definition, categorically including certain transport vehicles within the LMV class. To require a separate license for transport vehicles below this weight limit would render the specific inclusion of “transport vehicle” in the LMV definition redundant.
- Purpose of Statutory Distinctions: The additional, stricter requirements in the Act (e.g., higher age limit under Section 4(2), mandatory medical certificate for license renewal under Section 15, and longer training periods under Rule 31) should logically apply only to medium and heavy transport vehicles (those exceeding 7,500 kgs). These provisions are intended to ensure road safety for larger vehicles requiring greater skill and manoeuvrability.
- Avoiding Impractical Outcomes: Applying the extensive training syllabus (Rule 31) necessary for heavy transport vehicles to a driver seeking to operate a light transport vehicle, such as an autorickshaw (which is an LMV class transport vehicle), would defy logic and create an impractical outcome. The distinction between ‘Transport Vehicles’ and ‘LMVs’ in the licensing scheme must, therefore, be understood in the context of the weight limit.
- Upholding Mukund Dewangan: Although the Mukund Dewangan judgment failed to analyze every distinguishing provision (such as Sections 3, 4, 7, and 14), the fundamental outcome and reasoning were correct. The failure to notice these provisions did not constitute a “glaring error or omission” that would warrant declaring the decision per incuriam or altering the final result.
- Livelihood and Lack of Data: The reversal of Mukund Dewangan would negatively impact the livelihood (Article 19(1)(g)) of a large number of drivers. Furthermore, the insurance companies failed to present empirical data proving that LMV drivers operating light transport vehicles were a significant cause of increased road accidents.
Conclusion
The Supreme Court upheld the principle that a Light Motor Vehicle license is sufficient to drive any transport vehicle whose gross vehicle weight is below 7,500 kgs. The ruling clarifies the legal position for accident compensation claims and reinforces the harmonious interpretation of the MV Act, ensuring that specialized licensing requirements are restricted to medium and heavy transport vehicles. The Court also noted that while the decision is final, the Central Government should proceed with a comprehensive legislative amendment to resolve the statutory confusion permanently.
