MACT Territorial Jurisdiction Under Section 166(2): Insurer's Branch Office Cannot Determine Where Accident Claims Are Filed — Supreme Court

Overview

A significant ruling by the Supreme Court of India has brought clarity to a frequently litigated procedural question in motor accident compensation matters: can a claimant choose to file a compensation petition before a Motor Accidents Claims Tribunal (MACT) simply because the insurance company happens to operate a branch or head office within that Tribunal's territorial limits? The answer, as the Supreme Court has now definitively stated, is no.

In K Rashik Vs National Insurance Company Ltd. And Another (Civil Appeal No. 10706 of 2026, decided on 16/09/2026), the Supreme Court examined the scope and meaning of Section 166(2) of the Motor Vehicles Act, 1988, and settled important questions around which Tribunal has territorial jurisdiction to adjudicate a motor accident claim, whether an insurer can legitimately raise a jurisdictional objection, and how the stage of raising such an objection affects the legal standard to be applied.

Background Facts

On 25 October 2022, the appellant (referred to as "the claimant" throughout these proceedings) was riding his two-wheeler with his brother as a pillion rider. At Thatimaakulapalli Cross Road on the Nerabaillu to Yerravaripalem road, Y.V. Palem Mandal, District Tirupati, Andhra Pradesh, a mini truck driven by the second respondent struck their vehicle.

Following the accident:

  • The claimant received in-patient treatment at a hospital situated in Tirupati, Andhra Pradesh.
  • His brother lodged a First Information Report on 28.10.2022 at Yerravaripalem Police Station, District Tirupati.
  • The claimant's address as stated in the claim petition was: "No. 1-374, Sandu Street, Damalcheruvu Post, Pakala Mandal, Chittoor District, Andhra Pradesh- 517 152."
  • The driver of the offending vehicle also reportedly resided in Chittoor District.

Despite this, the claimant filed his compensation petition under Section 166 of the Motor Vehicles Act, 1988 before the Motor Accidents Claims Tribunal at Chennai — a location with no apparent factual connection to the accident or the parties.

The Jurisdictional Dispute: How It Unfolded

National Insurance Company Limited, impleaded as the first respondent, raised an objection challenging the territorial competence of the Chennai Tribunal. The insurer's position was straightforward — no element of the cause of action had materialised within the Chennai Tribunal's jurisdiction. The accident occurred in Tirupati, the claimant's stated residence was in Chittoor, and the FIR was registered in Tirupati.

The Chennai Tribunal dismissed this objection, reasoning that since the insurer conducted business in Chennai, the Tribunal could validly exercise jurisdiction.

Aggrieved by this order, the insurer filed a Civil Revision Petition under Article 227 of the Constitution of India before the Madras High Court. A learned Single Judge of the Madras High Court, by order dated 16.03.2026, overturned the Tribunal's ruling and directed transfer of the proceedings to the Tribunal at Chittoor, holding that the Chennai Tribunal lacked territorial jurisdiction.

The claimant then approached the Supreme Court challenging the High Court's order.

Arguments Before the Supreme Court

Claimant's Submissions

Mr. A. Sirajudeen, learned Senior Advocate for the claimant, advanced the following contentions:

  • The claimant resided and worked in Chennai, thereby vesting jurisdiction in the Chennai Tribunal under Section 166(2) of the Motor Vehicles Act, 1988.
  • The insurer maintained its head office at Chennai, and no prejudice would result from adjudication there.
  • Being a beneficial piece of legislation, the Motor Vehicles Act, 1988 deserves a liberal, purposive construction favouring accident victims over technical procedural objections raised by insurers.
  • Reliance was placed on the judgment of the Calcutta High Court in National Insurance Co. Ltd. vs Alpana Jana & others (F.M.A. 1454 of 2013 with C.A.N. 1858 of 2014).

Insurer's Submissions

Mr. S.L. Gupta, learned counsel for National Insurance Company Limited, countered thus:

  • The claimant's own claim petition disclosed his address as Chittoor District, Andhra Pradesh — not Chennai.
  • The accident occurred at Tirupati; treatment was received at Tirupati; the FIR was registered at Tirupati.
  • No aspect of the cause of action arose within the Chennai Tribunal's territorial jurisdiction.
  • The objection was not a mere technicality but a substantive point of law grounded in Section 166(2).
  • The High Court's order transferring proceedings to Chittoor was legally correct and warranted no interference.

Supreme Court's Analysis

Can the Insurer Question Territorial Jurisdiction?

Before addressing the merits of the jurisdictional question, the Court examined a preliminary issue: does an insurer have the legal standing to raise an objection to territorial jurisdiction at all?