Case Note & Summary
The dispute arose from a motor accident claim filed by the appellant, a claimant, before the Motor Accidents Claims Tribunal, Chennai, under Section 166 of the Motor Vehicles Act, 1988. The appellant was riding a two-wheeler with his brother on 25.10.2022 in District Tirupati, Andhra Pradesh, when a mini truck driven by the second respondent collided with them. The claimant underwent treatment at a hospital in Tirupati, and his brother lodged a First Information Report at Yerravaripalem Police Station, District Tirupati. In the claim application, the claimant's address was stated as No. 1-374, Sandu Street, Damalcheruvu Post, Pakala Mandal, Chittoor District, Andhra Pradesh. The insurer, National Insurance Company Limited, raised an objection to the territorial jurisdiction of the Chennai Tribunal, contending that no part of the cause of action had arisen within Chennai's jurisdiction and that under Section 166(2) of the Motor Vehicles Act, 1988, the Chennai Tribunal lacked territorial jurisdiction. The Tribunal, by order dated 11.07.2025, rejected the objection, holding that since the insurer had its business presence at Chennai, the Chennai Tribunal had jurisdiction. The insurer challenged this order before the Madras High Court under Article 227 of the Constitution of India. The High Court, by order dated 16.03.2026, set aside the Tribunal's order and transferred the proceedings to the Tribunal at Chittoor, Andhra Pradesh, holding that the accident occurred at Chittoor and the Chennai Tribunal lacked territorial jurisdiction. The claimant then preferred a civil appeal before the Supreme Court. The appellant argued that he resided and worked in Chennai, that Section 166(2) permitted filing where the claimant resides or carries on business, that the Act was a beneficial legislation to be interpreted in favour of claimants, and that the insurer had an office in Chennai causing no prejudice. The respondent insurer argued that the accident occurred at Tirupati, that the claimant's address was in Chittoor, that no part of the cause of action arose in Chennai, and that the insurer was entitled to raise the territorial jurisdiction objection as a party-respondent. The Supreme Court examined the averments in the claim application and found no pleading indicating any part of the cause of action arising within the territorial limits of the Chennai Tribunal. It noted that the claim application itself recorded the claimant's address in Chittoor District, Andhra Pradesh. The Court analyzed Section 166(2) and held that a claimant has four options for filing: at the place of accident, at the claimant's residence, at the claimant's place of business, or at the defendant's residence. The provision uses 'defendant resides' and not 'defendant carries on business'; therefore, the insurer's business presence at Chennai did not confer jurisdiction. The Court also held that an insurer impleaded as a party-respondent, as in this case, is entitled to raise all defences including territorial jurisdiction, relying on United India Insurance Co. Ltd. v. Shila Datta & Others. The Court rejected the argument that the Act being beneficial legislation should be interpreted to protect the claimant's interests beyond statutory limits. Consequently, the Supreme Court dismissed the appeal, upheld the High Court's order, and confirmed that the Motor Accidents Claims Tribunal at Chennai lacked territorial jurisdiction, with the proceedings to be entertained at Chittoor, Andhra Pradesh.
Headnote
A) Motor Vehicles - Territorial Jurisdiction - Claimant's Options Under Section 166(2) Motor Vehicles Act, 1988 - A claimant may file a claim application before the Tribunal having jurisdiction over the area where the accident occurred, or where the claimant resides, or where the claimant carries on business, or where the defendant resides; the place where the defendant carries on business is not included - In the present case, the accident occurred at Tirupati, Andhra Pradesh, the claimant's address was in Chittoor, Andhra Pradesh, and no part of the cause of action arose in Chennai; the insurer's office at Chennai did not constitute residence of the defendant - Held that the Tribunal at Chennai lacked territorial jurisdiction and the High Court correctly transferred the proceedings to the Tribunal at Chittoor (Paras 5-8). B) Insurance Law - Impleadment of Insurer as Party-Respondent - Sections 149(2), 170 Motor Vehicles Act, 1988 - An insurer impleaded as a party-respondent to a claim application can raise all grounds available to a person against whom a claim is made, including an objection to territorial jurisdiction; if only a noticee, the insurer is restricted to grounds under Section 149(2) - Relying on United India Insurance Co. Ltd. v. Shila Datta & Others, 2011 INSC 759, the Court held that the insurer, having been voluntarily impleaded as a defendant, was entitled to contest territorial jurisdiction - Held that the insurer's objection was maintainable (Paras 6-7). C) Statutory Interpretation - Beneficial Legislation and Territorial Jurisdiction - Motor Vehicles Act, 1988, Section 166(2) - The Motor Vehicles Act is a beneficial legislation but cannot be interpreted to confer jurisdiction beyond the express statutory options - The statute uses the expression 'defendant resides' and not 'defendant carries on business' in contradistinction to the claimant's options; therefore, an insurer's business presence in a location does not confer jurisdiction on the Tribunal there - Held that no relief could be granted on the ground of beneficial interpretation when the statutory language is clear (Paras 7-8).
Issue of Consideration
Whether the Motor Accidents Claims Tribunal at Chennai had territorial jurisdiction to entertain the claim application under Section 166(2) of the Motor Vehicles Act, 1988 when the accident occurred at Tirupati, Andhra Pradesh, the claimant's address was in Chittoor, Andhra Pradesh, and no part of the cause of action arose in Chennai, despite the insurer having an office in Chennai; and whether the insurer, when impleaded as a party-respondent, could raise an objection to territorial jurisdiction.
Final Decision
The Supreme Court dismissed the appeal, upholding the Madras High Court's order dated 16.03.2026. It held that the Motor Accidents Claims Tribunal at Chennai lacked territorial jurisdiction under Section 166(2) of the Motor Vehicles Act, 1988, as the accident occurred at Tirupati, Andhra Pradesh, the claimant's address was in Chittoor, Andhra Pradesh, and no part of the cause of action arose in Chennai. The insurer's office at Chennai did not confer jurisdiction because the statute refers to the defendant's residence, not its place of business. The proceedings were to be entertained at Chittoor, Andhra Pradesh.
Law Points
- Section 166(2) of Motor Vehicles Act
- 1988 provides four alternative forums for filing a claim: place of accident
- claimant's residence
- claimant's place of business
- or defendant's residence
- defendant's place of business is not included
- insurer impleaded as party-respondent can raise all defences including territorial jurisdiction
- beneficial legislation cannot override express statutory limits on jurisdiction
- territorial jurisdiction objection is not technical if no part of cause of action arises in the chosen forum
