Punjab & Haryana High Court Dismisses Revision Against ₹21,380 MACT Award, Holds No Appeal or Revision Maintainable Below ₹1 Lakh under Section 173(2) MV Act
Case Name: Nirbhai Singh & Another v. Darshan Singh @ Darshan Singh & Others
Date of Judgment: October 15, 2025
Citation: CR-1014-2024
Bench: Hon’ble Mrs. Justice Alka Sarin
Held: The Punjab & Haryana High Court dismissed a revision petition filed under Article 227 of the Constitution challenging a ₹21,380 compensation award passed by the Motor Accident Claims Tribunal, Patiala. Justice Alka Sarin held that in view of the 2022 amendment to Section 173(2) of the Motor Vehicles Act, 1988, no appeal is maintainable when the amount in dispute is below ₹1 lakh, and this statutory bar cannot be circumvented by filing a revision petition under Article 227. The Court clarified that supervisory jurisdiction under Article 227 is narrow and discretionary, exercisable only to ensure that subordinate courts act within their jurisdiction or to correct patent perversity, gross injustice, or violation of natural justice, not to re-appreciate evidence or act as an appellate court.
Summary: The petitioners, being the owner and driver of the offending vehicle, challenged the MACT award dated September 28, 2022, which had granted ₹21,380 to the claimant and held them, along with the insurer, jointly and severally liable. Their counsel contended that even though Section 173(2) bars appeals in cases involving compensation below ₹1 lakh, a revision under Article 227 remained permissible. Rejecting this argument, Justice Alka Sarin observed that the legislative amendment, which raised the threshold from ₹10,000 to ₹1 lakh, aimed to prevent unnecessary litigation over minor awards and reduce the High Court’s docket load. Relying on previous decisions including Bharti AXA General Insurance Co. Ltd. v. Sahab Singh & Ors. (CR-6131-2016, decided on 19.09.2016) and Shriram General Insurance Co. Ltd. v. Sandeep & Ors. (CR-1727-2025, decided on 21.03.2025), the Court reiterated that a party cannot use Article 227 to bypass a legislative restriction on appeals. The judgment also cited the Supreme Court’s decision in Shalini Shyam Shetty v. Rajendra Shankar Patil (2010 8 SCC 329), which laid down guiding principles for exercising superintendence jurisdiction, emphasizing judicial restraint, discipline, and the limited scope of intervention.
Decision: The High Court found no jurisdictional error or perversity in the MACT’s award and concluded that the revision petition was devoid of merit. Accordingly, the petition was dismissed as not maintainable, and all pending applications were disposed of. The award of ₹21,380 in favour of the claimant was upheld.