In a significant legal ruling on the scope of the Motor Vehicles Act, 1988 (MVA), the Supreme Court, comprising a bench of Justice Sanjay Karol and Justice N. Kotiswar Singh, held that a ‘Reach Stacker’ operated within an Inland Container Depot (ICD) is excluded from the definition of a “motor vehicle” under Section 2(28) of the MVA. The apex court further determined that roads inside a custom-bonded ICD do not constitute a “public place” under Section 2(34) of the Act. Consequently, the Court set aside a Delhi High Court judgment and restored the Motor Accidents Claims Tribunal (MACT) order rejecting a claim petition for compensation filed under Section 166 of the MVA.
Background of the Case
The case originated from an incident on September 5, 2013, when respondent Rishi Ranjan Mishra visited the Inland Container Depot (ICD) at Tughlakabad, New Delhi. He was struck by a Reach Stacker—a heavy industrial machine used to lift and stack shipping containers—which ran over his pelvic region. The accident caused severe injuries resulting in the amputation of his right leg, a 90 percent physical disability, and an alleged 100 percent functional disability.
The injured respondent filed a claim petition before the Motor Accidents Claims Tribunal (MACT), Saket Courts, seeking compensation of Rs. 75 lakhs. Respondent No. 3, New India Assurance Co. Ltd., opposed the claim by filing an application under Order VII Rule 11 of the Code of Civil Procedure, 1908 (CPC).
On January 9, 2018, the MACT allowed the insurer’s application and rejected the claim petition. The Tribunal observed that under Section 2(28) of the MVA, a vehicle must be mechanically propelled and capable of being used on the road to be a motor vehicle, and that special types of vehicles meant for use within enclosed premises are excluded.
However, on September 5, 2019, a Single Judge of the Delhi High Court reversed the MACT decision in MAC. App. No. 614/2018, relying on the precedent set in Western Coalfields Limited v. State of Maharashtra, holding that a Reach Stacker qualifies as a motor vehicle and that its operation within a restricted area does not strip it of this classification. The appellant, Container Corporation of India Limited, challenged the High Court’s ruling before the Supreme Court.
Arguments of the Parties
Senior Counsel Ms. Pinky Anand, representing the appellant Container Corporation of India Limited, contended that ICD Tughlakabad qualifies as enclosed premises under the MVA definition. It was argued that a Reach Stacker is a special type of machine adapted for restricted use within factories or enclosed industrial premises. Furthermore, the appellant highlighted that the roads inside the ICD are specifically reinforced to sustain the enormous weight of Reach Stackers—which weigh approximately 71.8 metric tonnes unladen and up to 102 metric tonnes at full capacity—far exceeding the permissible gross vehicle weight limit of 49 to 55 tonnes prescribed under the Ministry of Road Transport and Highways Gazette Notification S.O. 728(E) dated July 16, 2018.
Counsel Mr. Yadav Narender Singh, appearing for the claimant, argued that the ICD spans roughly 10 square kilometers with extensive interconnecting roads accessible to authorized members of the public, thereby constituting a public place. He submitted that a Reach Stacker meets the criteria of a motor vehicle because it possesses a high-capacity engine, is mounted on chassis and rubber tyres, moves containers across the ICD, is operated by a driver, and faces no technical barrier preventing it from moving on regular roads.
Ms. Shatakshi Singh, appointed as Amicus Curiae by the Court, supported the claimant’s position.
Court’s Analysis and Observations
The Supreme Court examined two central issues: whether the internal roads of an ICD constitute a “public place” under Section 2(34) of the MVA, and whether a Reach Stacker falls within the definition of a “motor vehicle” under Section 2(28) of the MVA.
Addressing the nature of the premises, the Court referred to Tarachand Logistic Solutions Ltd. v. State of A.P., which analyzed Bolani Ores Ltd. v. State of Orissa, stating: “when the members of the public are not allowed access inside an area without prior permission and when there is check on ingress and egress to ensure that no unauthorized person have access to the premises, the same would be an enclosed premise and not a ‘public place’.”
The Court observed that since ICD Tughlakabad is a custom-bonded area under Section 7 of the Indian Customs Act, 1962, entry is restricted strictly to authorized personnel. Thus, members of the general public cannot claim entry as a matter of right, and the roads inside do not constitute a “public place” under Section 2(34) of the MVA.
Evaluating whether the Reach Stacker is a motor vehicle, the Court considered several precedents cited by the parties, including Goodyear India Ltd. v. Union of India, Ultratech Cement Ltd. v. State of Gujarat, Central Coal Fields Ltd. v. State of Orissa, Bose Abraham v. State of Kerala, Govt. of A.P. v. Road Rollers Owners Welfare Assn, Rajasthan SRTC v. Santosh, and Natwar Parikh & Co. Ltd. v. State of Karnataka.
Applying the dominant use test from Goodyear India Ltd., the Bench highlighted: “Merely because the areas on which such heavy-movers traverse might sometimes include roads also is not enough to hold that they were ‘adapted for use upon roads’. Such use of the heavy-mover on the road may only be ancillary or incidental to the main use of it. Emphasis in the definition must be on the words ‘use upon road’ as those words would denote the principal or dominant use and not where it may move incidentally.”
The Court held that the utility of Reach Stackers is limited to specific industrial applications such as handling containers at ports and terminals. Relying on Ultratech Cement Ltd., the Court reasoned that even though a Reach Stacker might possess features of a mechanically propelled vehicle on wheels, it falls squarely within the second, exclusionary part of Section 2(28) of the MVA as a vehicle of a special type adapted for use only in enclosed premises.
The Bench observed: “The way the exclusion functions does not require the characteristic of the motor vehicle to be absent but instead it recognises that despite having the characteristics of a motor vehicle, certain types of vehicles cannot be equated to those vehicles that are generally understood to be ‘motor vehicles’.”
The Court also noted a communication from the Joint Transport Commissioner & Secretary, RTA Hyderabad, confirming that Reach Stackers are not prescribed under the Motor Vehicle Rules, cannot operate on public roads, and do not require registration under Section 39 of the MVA.
The Court added a protective caveat regarding future accidents: “This should, however, not restrict a claimant’s right to seek compensation under the MVA should such an untoward incident ever take place within the four walls of the ICD with a ‘regular’ vehicle that ordinarily plies on roads that may have been taken into the restricted area by officials of the department or some other person connected with the ICD or its processes.”
The Decision
The Supreme Court allowed the appeal, set aside the Delhi High Court judgment dated September 5, 2019, and restored the order of the Tribunal. Clarifying the financial aspect, the Court directed that any amount already paid to the claimant shall not be subject to recovery. No order as to costs was made.
Case Details:
Case Title: Container Corporation of India Limited v. Rishi Ranjan Mishra & Ors.
Case No.: Civil Appeal No. 10526 of 2024
Bench: Justice Sanjay Karol and Justice N. Kotiswar Singh
Date: July 29, 2026
