A claimant who lives in Chittoor and was injured in Tirupati cannot file his claim in Chennai

Justices Ujjal Bhuyan and Atul S. Chandurkar upheld the transfer of a motor accident claim, holding Section 166(2) cannot be read beyond its plain language.

Section 166(2) of the Motor Vehicles Act, 1988 lets a claimant choose where to file: the Tribunal for the area where the accident occurred, or where the claimant resides or carries on business, or where the defendant resides. The claimant in this case lived in Chittoor and was injured in Tirupati, and filed his application in Chennai. On 16 September 2026 the Supreme Court upheld the Madras High Court's order sending the claim to Chittoor, and explained why a statute meant to relieve hardship still has to be read as it is written.

The accident and the objection

On 25 October 2022 the appellant was riding his two-wheeler with his brother when a mini truck driven by the second respondent struck them. The accident occurred in District Tirupati, Andhra Pradesh. He filed a claim application under Section 166 of the Act before the Motor Accidents Claims Tribunal at Chennai. The insurer, on being served, raised an objection to the territorial jurisdiction of that Tribunal.

The Tribunal at Chennai held that it had jurisdiction. A Single Judge of the Madras High Court set that order aside on 16 March 2026 and directed that the entire proceedings be transmitted to the Tribunal at Chittoor. The claimant appealed.

Why Section 21 of the Code did not help

The appellant's argument drew on a line of cases in which objections to territorial jurisdiction had failed. The Court distinguished them on a point of stage. In each of those cases the objection had been taken at the appellate stage, which attracts Section 21(1) of the Code of Civil Procedure — a party raising such an objection then has to show that a failure of justice was caused by the exercise of jurisdiction by a forum that lacked it.

Here the position was different in both directions. The claimant himself impleaded the insurer as a party to the claim application, and the insurer raised its objection before the Tribunal itself, not after an award. The claim still awaits adjudication on merits. In those circumstances the requirements of Section 166(2) have to be satisfied on their own terms, and Section 21(1) of the Code is not attracted at all.

Nothing connected the case to Chennai

On the pleadings the answer was straightforward. The claimant resides at Chittoor in Andhra Pradesh, as pleaded. The accident occurred in District Tirupati. There was no averment in the claim application that the claimant carries on business anywhere else. Even the driver of the offending vehicle was stated to reside in District Chittoor. No part of the cause of action had arisen within the local limits of District Chennai so as to clothe the Tribunal there with territorial jurisdiction, and the High Court was right to correct the Tribunal's error.

How far a beneficial statute bends

The Court accepted the premise behind the appellant's case. The Act of 1988 is legislation intended, among other objects, to redress the hardships flowing from a motor vehicle accident, and it must be interpreted with those objectives in mind. But it drew a limit around purposive construction: an interpretation that does not flow from a plain reading of the statutory provisions, even on a purposive approach, cannot be commended. An interpretation without statutory support cannot be accepted, and one in tune with the plain language of the statute ought to be preferred.

Order

The order of the Single Judge of the Madras High Court dated 16 March 2026 was upheld, and the direction to transmit the entire proceedings from the Tribunal at Chennai to the Tribunal at Chittoor was held to have been correctly issued. The claim application is to be tried by the Tribunal at Chittoor in accordance with law, expeditiously. The civil appeal was dismissed with no order as to costs, and the pending interlocutory application disposed of.