Roads Inside ICD Not Public Place Under MVA; Claimants May Seek Compensation For Accidents By Regular Vehicles Within Depot: Supreme Court

The Supreme Court also set aside the Delhi High Court’s judgment and restored the Tribunal’s finding rejecting a Motor Vehicles Act compensation claim arising from an accident involving a Reach Stacker inside the Inland Container Depot.

The Court was hearing an appeal by Container Corporation of India Limited in a claim arising from an accident at the Inland Container Depot, Tughlakabad, where a Reach Stacker hit the claimant and ran over his pelvic region, resulting in amputation of his right leg and serious disability.

A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh, while holding that roads inside ICD do not fall within Section 2(34) MVA, observed: “Since the ICD is a custom bonded area within the meaning of Section 7 of the Indian Customs Act 1962, i.e. the place for unloading and loading of goods imported and exported, it only stands to reason that only those persons who are duly authorized by the competent authority will have access to the same. This fortifies the conclusion that it is not a place that public has a right to access. As such, the roads within ICD, to our view do not constitute ‘public place’ as defined under Section 2 (34) of the MVA.”

However, the Bench further added: “We have held that ICD is not a ‘public place’ within the meaning of Section 2 (34) of MVA. 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.”

Senior Advocate Pinky Anand appeared for Container Corporation, while Advocate Yadav Narender Singh appeared for the claimant. Advocate Shatakshi Singh appeared as Amicus Curiae.

Background

The claimant had sought ₹75 lakhs as compensation under Section 166 of the Motor Vehicles Act after being injured by a Reach Stacker inside the Inland Container Depot.

The Tribunal rejected the claim, holding that the Reach Stacker did not fall within the statutory meaning of “motor vehicle” for the purposes of the Motor Vehicles Act. The Delhi High Court reversed that view, holding that the restricted area in which the Reach Stacker plied would not take it outside the classification of a motor vehicle.

Container Corporation approached the Supreme Court, contending that the ICD was an enclosed premises, that the Reach Stacker was a special vehicle used in such premises, and that roads within the ICD were specially constructed to bear its weight.

Court’s Observations

The Court first examined Section 2(34) of the Motor Vehicles Act, which defines “public place” as a road, street, way or other place, whether a thoroughfare or not, to which the public have a right of access.

Referring to Tarachand Logistic Solutions Ltd. v. State of A.P. (2025), the Court noted: “A motor vehicle which is not adopted for use upon roads to which the public have no right of access is not a motor vehicle. It was held that dumpers and rockers would not be taxable as long as those were working solely within the private premises of the respective owners.”

The Court held that the expression “thoroughfare or not” may indicate restricted access, but the relevant question remains whether the public has a right of access.

The Court found that ICD operations involve movement of heavy machinery and shipping containers on specially designed roads, and ordinary members of the public cannot claim entry as a matter of right.

The Court then considered whether a Reach Stacker is a motor vehicle under Section 2(28) MVA.

The Court noted that a Reach Stacker is used to lift and move heavy materials such as shipping containers and that its unladen weight was about 71.8 metric tonnes, rising to about 102 metric tonnes at full capacity.

The Court observed: “Well, to say that only because a vehicle has rubber tyres and is on chassis that it is suitable for public roads, would be a rather simplistic view of the whole situation. The concerned authority has notified the permissible weights, and it goes without saying that if a particular vehicle goes against the guidelines mentioned therein, its suitability is obviously impacted.”

Relying on Bolani Ores Ltd. v. State of Orissa (1974), Goodyear India Ltd. v. Union of India (1997), and Ultratech Cement Ltd. v. State of Gujarat (2026), the Court held that the test is not merely whether the machine can move, but whether it is adapted or suitable for use on public roads.

The Court noted that the surfaces inside the ICD were specifically designed to bear the weight of Reach Stackers.

The Court observed: “It is an undisputed fact that the surfaces within ICD are specifically designed to bear the weight of these vehicles. If special care has been taken to design roads in accordance with what will be used on them, it stands to reason that those roads, that have not taken into account regular use of such heavy vehicles will be unfit.”

The Court further stated: “Since it is vehicle dedicated to a particular kind of work which takes place within duly notified areas, it would fall into the second half of the definition of ‘motor vehicles’, i.e. the exclusion.”

It clarified that the exclusion in Section 2(28) does not require all characteristics of a motor vehicle to be absent. Rather, it recognises that despite having some such characteristics, certain special vehicles cannot be equated with vehicles generally understood as motor vehicles.

The Court also considered a notification stating that Reach Stackers are not motor vehicles and do not require registration under Section 39 of the Motor Vehicles Act.

The Court clarified: “It is not that every vehicle that is not registered would be taken out of the scope of this Act. If a vehicle plies on the road without registration, that would be in violation of the provisions of the MVA. But in the present case, a motor vehicle is what is required to be registered.”

It held that where the concerned authority states that a Reach Stacker is not a motor vehicle, registration under Section 39 would not arise.

Before parting, the Court added an important caveat. It clarified that the ruling that ICD is not a public place under Section 2(34) MVA would not defeat every claim arising inside such restricted premises.

Conclusion

The Supreme Court allowed the appeal, set aside the Delhi High Court judgment and restored the Tribunal’s findings. It clarified that if any money had already been paid to the claimant, the same would not be recovered.

Cause Title: Container Corporation of India Limited v. Rishi Ranjan Mishra & Others (Neutral Citation: 2026 INSC 763)

Appearances

Appellant: Senior Advocate Pinky Anand, with Advocates Rishi K. Awasthi, Piyush Vatsa, Amit V. Awasthi, Rahul K. Gupta, Samrat Pasriccha, Nayoleeka Purty, Antariksh Singh, Saudamini Sharma, Ritu Arora, Gouri Goburdhun, Shashank Chamolin, Adeti Salooja, Vinayak Tiwari and Punit Vinay, AOR

Respondents: Yadav Narender Singh, AOR; Shatakshi Singh, Amicus Curiae; Nidhi, AOR, with Advocates Om Kumar and Dhruv Maheshwari

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