The Allahabad High Court has issued a clear directive reinforcing that pending motor accident claims cannot be dismissed on grounds of limitation while a Supreme Court matter on the issue remains sub judice. This order ensures procedural fairness and aligns lower tribunals with the Supreme Court’s interim stance, offering critical relief to claimants caught in procedural limbo.
Background & Facts
The Dispute
The petitioners, Sita Ram and another, filed a claim petition under Section 164 of the Motor Vehicles Act, 1988 (as amended in 2019), read with Rule 3 of the U.P. Claims Tribunal Rules, 1998, before the Motor Accident Claims Tribunal, Gorakhpur. The claim petition was registered as Misc. Case No. 678 of 2024 on 13.06.2024. The petitioners sought the Tribunal to treat the petition as a regular claim matter and decide it expeditiously, arguing that the petition should not be dismissed or delayed on account of alleged limitation under Section 166(3) of the Motor Vehicles Act, 1988.
Key Facts
- The claim petition was filed on 13.06.2024 before the Motor Accident Claims Tribunal, Gorakhpur.
- The petitioners contended that the claim was not barred by limitation and sought regular numbering of the case.
- The Tribunal had not yet assigned a regular case number, treating the petition as pending or provisional.
- The petitioners were seeking adjudication on the merits without procedural obstruction.
Procedural History
- 13.06.2024: Claim petition filed before Motor Accident Claims Tribunal, Gorakhpur as Misc. Case No. 678 of 2024.
- Before 02.07.2026: Petitioners approached the Allahabad High Court via writ petition (WP(C) No. 15200 of 2026) seeking direction to allot regular number and decide the claim.
- 04.11.2025: Supreme Court passed an order in Special Leave to Appeal (C) No. 8412-8413 of 2023, directing that no claim petition shall be dismissed on the ground of limitation during its pendency.
- 02.07.2026: Allahabad High Court heard the writ petition and relied upon the Supreme Court’s directive.
Relief Sought
The petitioners sought:
- A direction to the Motor Accident Claims Tribunal to allot a regular case number to Misc. Case No. 678 of 2024.
- That the claim petition be decided without regard to Section 166(3) of the Motor Vehicles Act, 1988.
- That the matter be decided as early as possible.
The Legal Issue
The central question was whether a Motor Accident Claims Tribunal may refuse to assign a regular number or delay adjudication of a claim petition on the ground of limitation, in light of the Supreme Court’s directive that such petitions shall not be dismissed on limitation grounds during the pendency of its pending appeal.
Arguments Presented
For the Petitioner
The petitioners, through counsel Adya Prasad Tewari, argued that the claim petition was duly filed and that the Supreme Court’s order dated 04.11.2025 in SLP(C) No. 8412-8413 of 2023 explicitly prohibits dismissal of any claim petition on the ground of limitation. They contended that refusal to assign a regular number or delay proceedings amounted to a de facto dismissal and violated the spirit of the Apex Court’s direction.
For the Respondent
The respondents, through counsel Chandan Sharma, did not oppose the petition. The counsel for the Allahabad High Court confirmed the existence and binding nature of the Supreme Court’s order and affirmed that all tribunals and courts are bound to comply with it.
The Court's Analysis
The Court examined the Supreme Court’s order dated 04.11.2025, which explicitly directed that during the pendency of the matter before it, no Motor Accident Claim Tribunal or High Court shall dismiss any claim petition on the ground of limitation. The Court held that this directive is not merely advisory but binding on all subordinate forums.
"All Motor Accident Claim Tribunals and High Courts have been directed that during pendency of the matter before Hon'ble Apex Court, claim petitions shall not be dismissed as being barred by limitation."
The Court observed that the petitioners’ claim was not only timely filed but also fell squarely within the protective ambit of the Supreme Court’s order. Denial of a regular case number would effectively stifle the claimant’s right to adjudication and amount to procedural denial of justice. The Court emphasized that the Tribunal’s duty is to assign a regular number and proceed to adjudication, not to impose additional hurdles.
The Court further noted that the petitioners had not sought any extraordinary relief beyond compliance with a binding Supreme Court directive. There was no dispute over the maintainability of the claim, nor any allegation of fraud or mala fide delay. The only issue was procedural non-compliance by the Tribunal.
The Verdict
The writ petition was allowed. The Motor Accident Claims Tribunal, Gorakhpur, is directed to allot a regular case number to Misc. Case No. 678 of 2024 and proceed with the adjudication of the claim petition. The Tribunal is directed to make every endeavour to decide the matter preferably within six months from the date of production of the certified copy of this order. No costs are awarded.
What This Means For Similar Cases
Limitation Cannot Be Used as a Procedural Shield
- Practitioners may now cite this order to compel Tribunals to assign regular numbers to pending claims, even if limitation is raised.
- Tribunals must treat claims as active matters once filed, pending final determination by the Supreme Court.
Compliance with Apex Court Directives Is Mandatory
- All subordinate forums must immediately implement Supreme Court interim orders without requiring further clarification.
- Delay in assigning case numbers or refusing to proceed on technical grounds violates the spirit of mandamus and judicial hierarchy.
Timely Adjudication Is Now Enforceable
- The six-month timeline set by the Court provides a clear benchmark for litigants to demand expeditious disposal.
- Failure to comply may be challenged via contempt proceedings or further writ petitions.
