The Supreme Court of India recently issued a landmark judgment allowing drivers with a light motor vehicle (LMV) license to operate transport vehicles weighing less than 7,500 kg without needing additional authorization.
This decision came from a five-judge Constitution bench led by Chief Justice D.Y. Chandrachud, which also included Justices Hrishikesh Roy, P.S. Narasimha, Pankaj Mithal, and Manoj Misra.
The ruling has significant implications for both drivers and the insurance industry, which has often denied claims in accidents involving LMV license holders driving small transport vehicles, arguing they lacked proper authorization.
The case arose from disputes over insurance claims in accidents involving transport vehicles operated by drivers holding LMV licenses. Insurance companies argued that, based on legal distinctions between LMV and transport vehicles, any transport vehicle—even one under 7,500 kg—would require a separate license or endorsement.
However, the bench interpreted the Motor Vehicles Act of 1988 and the Central Motor Vehicles Rules of 1989, concluding that light transport vehicles under 7,500 kg are covered by an LMV license.
According to the bench, requiring a separate endorsement for these vehicles would contradict the intent of the legislation, which seeks to simplify and streamline licensing for drivers.
The court referred to the 2017 case Mukund Dewangan v. Oriental Insurance Co. Ltd., where a three-judge bench similarly held that LMV license holders could operate transport vehicles weighing up to 7,500 kg. Insurance companies had challenged this view, citing concerns over road safety.
“It is a clear signal that the legislature did not wish to maintain a distinction between the two classes of vehicles. Such an explicit and specific definition leaves no room for ambiguity. Considering the emphatic nature of the definition given in Section 2(21), which would suggest a strict interpretation, it would be logical to conclude that a light motor vehicle would mean a transport vehicle, omnibus, road roller, tractor, or motor car, provided the weight does not exceed 7,500 kg.”
However, the Supreme Court bench dismissed these concerns, noting that no empirical evidence links an increase in accidents to LMV license holders driving transport vehicles under 7,500 kg. The court emphasized that policy changes affecting road safety should be based on factual data, not assumptions.
In addressing road safety, the court acknowledged that the Motor Vehicles Act is designed to protect public welfare, but cautioned that the judiciary should not overstep its role by making policy decisions. It reiterated that legislative bodies are responsible for crafting policies and amending laws, while the judiciary's role is to interpret existing statutes.
Justice Hrishikesh Roy, writing for the bench, remarked on the need for a dynamic licensing system that evolves with technological advancements, like autonomous vehicles and app-based transportation services. The court acknowledged that while the Motor Vehicles Act has been amended, further changes are anticipated to address gaps in the legislation. These amendments, the court hopes, will consider road safety comprehensively while supporting the livelihoods of drivers who depend on their LMV licenses for employment in operating lighter transport vehicles.
In summary, the ruling clarifies that LMV license holders can legally operate transport vehicles up to 7,500 kg, preserving both their employment opportunities and the efficiency of the licensing system.
It also reaffirms the boundaries between judicial interpretation and legislative policymaking, stressing that any future policy adjustments for road safety should come from legislative amendments rather than judicial rulings.
Case Title:
M/S. BAJAJ ALLIANCE GENERAL INSURANCE CO.LTD. VS. RAMBHA DEVI - C.A. No. 841/2018 - Diary Number 29686 / 2017 - 06-Nov-2024
(Uploaded On 06-11-2024 12:12:44)
Comments