Clarifying Who Can Drive a Transport Vehicle with an LMV License

The Supreme Court’s decision affirmed that individuals holding an LMV license can legally drive a Transport Vehicle weighing less than 7,500 kgs, without the need for a separate endorsement. The ruling clarified the law and addressed concerns regarding the sufficiency of training for drivers of such vehicles, emphasizing the need for a balanced, practical approach to vehicle licensing.

This judgment is significant as it simplifies the licensing requirements and ensures that small-scale commercial activities using LMVs (like auto-rickshaws) are not burdened by unnecessary legal hurdles. It also highlights that the Court will not allow unsubstantiated safety concerns to override reasonable interpretations of the law.

Case: M/S. Bajaj Alliance General Insurance Co. Ltd. v. Rambha Devi

Date: 6 November 2024

Justices: Chief Justice Dr. Dhananjaya Y. Chandrachud, Justice Hrishikesh Roy, Justice Pamidighantam S. Narasimha, Justice Pankaj Mittal, Justice Manoj Misra

Background

The Bajaj Alliance Insurance v. Rambha Devi case revolved around whether a person with a "Light Motor Vehicle" (LMV) license could drive a "Transport Vehicle" weighing less than 7,500 kgs, without needing a specific endorsement. The Motor Vehicles Act, 1988 (MV Act) classifies vehicles based on weight, with LMVs being those weighing less than 7,500 kgs.

In 1994, a new category of “Transport Vehicles” was introduced, covering vehicles used to transport goods and passengers. However, a question arose regarding whether a person holding only an LMV license could legally drive these Transport Vehicles, particularly those under 7,500 kgs in weight.

In 2017, the Supreme Court addressed this in Mukund Dewangan v. Oriental Insurance Company and ruled that LMV license holders could indeed drive Transport Vehicles under 7,500 kgs. Despite this, insurance companies continued to dispute this view, fearing that inadequately trained drivers would use these vehicles.

In 2018, a Division Bench of the Court raised concerns that key provisions of the MV Act were not considered in Mukund Dewangan and referred the issue to a larger bench. In 2023, a Three-Judge Bench also questioned the correctness of Mukund Dewangan. Finally, the matter reached a Constitution Bench for clarification.

Supreme Court's Decision

The five-judge Constitution Bench of the Supreme Court, led by Justice Hrishikesh Roy, unanimously upheld the earlier decision in Mukund Dewangan. The Court ruled that a person holding an LMV license is indeed entitled to drive a Transport Vehicle weighing less than 7,500 kgs without needing an additional endorsement.

Key Reasons for the Decision:

1. Harmonious Interpretation of the Law: The Court referred to Section 2(21) of the MV Act, which defines an LMV, and Section 2(47), which defines a transport vehicle. The Court found that a transport vehicle weighing less than 7,500 kgs could be classified as an LMV. If LMV license holders were not allowed to drive such vehicles, it would create unnecessary complications for people wishing to use vehicles like auto-rickshaws or small trucks for commercial purposes. The Court stressed that a separate endorsement requirement would go against the legislative intent of simplifying licensing (¶44.3, ¶66).

2. Avoiding Impractical Outcomes: The Court also highlighted the absurdity of requiring a separate endorsement for LMVs that are transport vehicles, such as an auto-rickshaw, which would involve extensive training requirements. Requiring a driver of an auto-rickshaw to undergo the same level of training as for a heavy transport vehicle would result in an impractical and unreasonable outcome (¶79-81).

3. Legislative Intent of Simplification: The Court noted that the 1994 amendment to the MV Act replaced medium and heavy goods vehicle categories with a broader “Transport Vehicle” category, intending to simplify the licensing procedure. Thus, the term "Transport Vehicle" should not require additional endorsements when it falls under the LMV category (¶127).

4. No Empirical Data to Support Safety Concerns: The Court further observed that no empirical data suggested that allowing LMV license holders to drive vehicles under 7,500 kgs contributed to an increase in road accidents. The arguments raised by the insurance companies, suggesting an increase in accidents due to the Mukund Dewangan ruling, were not backed by any conclusive evidence (¶117, ¶123).

Impact

This decision removes ambiguity for drivers of small transport vehicles and ensures consistency in the application of the law. It could lead to better clarity in future cases involving vehicle classification and licensing. Additionally, it emphasizes that safety regulations should be based on solid data, and not on hypothetical risks. The ruling could have far-reaching implications in the broader context of vehicle regulations and insurance claims.

Read the full judgement here: Document