Reach Stacker Used Only Inside an Inland Container Depot Is Not a ‘Motor Vehicle’ Under Section 2(28) MV Act; Rubber Tyres and Mechanical Propulsion Alone Do Not Make a ‘Motor Vehicle’; ICD Is Not a ‘Public Place’: Supreme Court
Case Name: Container Corporation of India Limited v. Rishi Ranjan Mishra & Ors.
Date of Judgment: 29 July 2026
Citation: 2026 INSC 763
Bench: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh
Held: The Supreme Court held that a Reach Stacker used for handling containers within an Inland Container Depot falls within the exclusionary part of Section 2(28) of the Motor Vehicles Act, 1988 and is therefore not a “motor vehicle” for purposes of the Act, notwithstanding that it is mechanically propelled, mounted on wheels and capable of movement. The decisive considerations are whether the vehicle is adapted or suitable for ordinary road use, its dominant purpose and whether it is a special type designed for use only within a factory or enclosed premises. The Court further held that the Tughlakabad ICD, being a customs-bonded area with controlled entry and no right of access to the general public, is not a “public place” under Section 2(34) MV Act.
Summary: The claimant suffered catastrophic injuries inside the Inland Container Depot, Tughlakabad, when a Reach Stacker ran over his pelvic region. His right leg was amputated and his physical disability was assessed at 90%. He sought ₹75 lakh compensation under Section 166 of the Motor Vehicles Act. The Motor Accident Claims Tribunal rejected the claim at the threshold on the ground that a Reach Stacker used inside enclosed premises was not a “motor vehicle” within Section 2(28). The Delhi High Court reversed that conclusion, prompting Container Corporation of India to approach the Supreme Court.
The Court first considered whether the ICD constituted a “public place”. It noted that the depot was a customs-bonded area used for loading and unloading imported and exported goods, with access restricted to persons authorised by the competent authorities. The fact that extensive internal roads existed within the premises did not confer upon the public a right of access. Accordingly, the internal roads of the ICD did not qualify as a public place under Section 2(34) MV Act.
Turning to the machine itself, the Court stressed that “adapted for use upon roads” means suitable or fit for road use, and mere ability to physically move on a road is insufficient. The Reach Stacker weighed approximately 71.8 metric tonnes unladen and about 102 metric tonnes when fully loaded, significantly exceeding the statutory permissible weights referred to by the Court. Roads within the ICD were specially constructed to sustain such heavy equipment. Its dominant utility was also highly specialised—handling and transporting containers within ports, terminals and similar industrial environments.
Relying particularly on Bolani Ores, Goodyear India and Ultratech Cement, the Court held that the exclusion in the second part of Section 2(28) is crucial. A vehicle may possess characteristics ordinarily associated with a motor vehicle yet remain excluded where it is a special-purpose machine adapted for use only within enclosed premises. The Reach Stacker exceeded permissible road weight, required specialised surfaces, was transported after dismantling and lacked ordinary road-safety features. It therefore fell squarely within the statutory exclusion.
Decision: The Supreme Court allowed the appeal, set aside the Delhi High Court judgment and restored the MACT’s decision, thereby holding that the Reach Stacker involved in the accident was not a motor vehicle under Section 2(28) MV Act. However, any compensation already paid to the claimant was protected from recovery. Importantly, the Court clarified that its conclusion that the ICD is not a “public place” does not prevent a claimant from seeking compensation under the MV Act where an accident inside the ICD involves a regular vehicle which ordinarily plies on roads.