M/s. Bajaj Allianz General Insurance Co. Ltd. vs. Rambha Devi & Ors.
Background
In motor accident claims, insurance companies frequently argue they need not pay compensation because the driver held only a "light motor vehicle" (LMV) licence while driving a heavier "transport vehicle," making the licence invalid for that vehicle. A three-judge bench in Mukund Dewangan v. Oriental Insurance Co. (2017) had ruled that an LMV licence covers such transport vehicles up to 7,500 kg, but a later two-judge bench doubted this, noting that certain provisions of the Motor Vehicles Act (on minimum age, mandatory medical certificates, and licence validity periods for transport vehicles) had not been placed before the Mukund Dewangan bench. This order deals with dozens of insurance companies' connected appeals raising the same question.
Decision Breakdown
This is not a final judgment but an interim referral order. The three-judge bench agreed that important statutory provisions were indeed overlooked in Mukund Dewangan and that the controversy needed to be revisited. Since the earlier ruling was itself by three judges, the Court held it could only be properly reconsidered by a bench of more than three judges, and directed the Registry to place the matters before the Chief Justice of India to constitute such a larger bench. It also recorded insurers' assurance that compensation already directed under the Mukund Dewangan principle had been or would be paid.
Lesson Learnt
Even a settled Supreme Court precedent can be sent back for a fresh, larger-bench look if a later bench identifies relevant law that was not considered earlier, so on technical questions like licence classification for insurance liability, litigants should track whether the "settled" position is itself under review.