Motor Vehicle Act: Supreme Court Says Special Type Vehicles Used Only in Enclosed Premises Excluded

The Supreme Court has held that for a machine to qualify as a motor vehicle under Section 2(28) of the Motor Vehicles Act (MV Act), it must be mechanically propelled and adapted for use upon roads. However, vehicles of a special type adapted for use only in a factory or any other enclosed premises are expressly excluded from the definition, even if they possess the technical characteristics of motor vehicles.

A Bench of Justices Sanjay Karol and N Kotiswar Singh held that a Reach Stacker is a special type of vehicle adapted for use only in enclosed premises and is therefore excluded from the definition of a motor vehicle under Section 2(28) of the Motor Vehicle Act.

Why is a Reach Stacker not a ‘motor vehicle’ under the MV Act?

Court held that the Reach Stacker, though mechanically propelled and fitted with tyres and a chassis, is a vehicle dedicated to a particular kind of work carried out within duly notified and restricted areas. It therefore falls within the exclusion contained in the definition of a ‘motor vehicle’ under Section 2(28) of the Act.

Court noted that merely because a vehicle has rubber tyres and is mounted on a chassis, it cannot be concluded that it is suitable for use on public roads.

“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 Bench said.

Court further noted that the concerned authority had prescribed permissible weights, and if a particular vehicle does not comply with those requirements, its suitability for use on roads is affected.

Court also examined the nature and use of Reach Stackers. It noted that they are used in connection with containers, ports and terminals, steel and aluminium and other industries where heavy items have to be lifted and transported from one area to another.

“Because its application is for a limited set of tasks and to a limited kind of industries, in our considered view, the utility test also is decided in favour of the appellants,” the Bench said.

Court therefore held that since the Reach Stacker is a vehicle dedicated to a particular kind of work carried out within duly notified areas, it falls within the second half of the definition of ‘motor vehicle’, which provides for its exclusion.

The Bench clarified that the exclusion does not require the vehicle to lack the characteristics of a motor vehicle. Instead, it recognises that even though certain vehicles may possess such characteristics, they cannot be treated as motor vehicles for the purposes of the Act when they are of a special type and adapted for use only within enclosed premises.

Is an Inland Container Depot a ‘public place’ under the MV Act?

The Supreme Court also held that an Inland Container Depot (ICD) is not a ‘public place’ within the meaning of Section 2(34) of the MV Act.

Court explained that a ‘public place’ refers to a thoroughfare or a location to which the public has a right of access. Areas where entry and exit are restricted and access is limited to authorised persons would therefore not qualify as public places.

“Areas restricted by ingress/egress controls, such as a custom-bonded Inland Container Depot, where access is granted only to authorized persons, do not constitute a public place,” Court said.

The Bench noted that the ICD in question is a custom-bonded area within the meaning of Section 7 of the Indian Customs Act, 1962, where goods imported and exported are unloaded and loaded.

It therefore held that only persons duly authorised by the competent authority would have access to the area.

“This fortifies the conclusion that it is not a place that the 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 MV Act,” the Bench said.

Registration under Section 39 applies only to motor vehicles

The Supreme Court also held that the requirement of registration under Section 39 of the MV Act applies only to motor vehicles.

“If a machine is determined not to be a motor vehicle under the Act, the absence of registration does not trigger the regulatory consequences otherwise applicable to vehicles,” the Bench said.

Since the Reach Stacker was held not to be a motor vehicle under the Act, Court concluded that the registration requirement under Section 39 was not applicable to it.

What was the case about?

The appeal was filed by Container Corporation of India Limited challenging the September 5, 2019 judgment of the Delhi High Court.

The Motor Accident Claims Tribunal (MACT), Saket, had answered the issue in the negative in a compensation petition filed under Section 166 of the MV Act by Rishi Ranjan Mishra.

As per the facts of the case, on September 5, 2013, Mishra visited the Inland Container Depot at Tughlakabad, New Delhi, when the vehicle in question hit him and ran over his pelvic region, causing severe injuries.

His right leg had to be amputated and he underwent several surgeries. His physical disability was assessed at 90%, which he claimed amounted to 100% functional disability. Before the tribunal, he sought compensation of Rs 75 lakh.

The claimants argued that the Reach Stacker qualified as a motor vehicle because it had a high-capacity engine, was mounted on tyres and a chassis, was used for shifting containers within the ICD, was driven by a driver and had no technical barrier preventing it from moving on roads.

The Supreme Court, however, rejected this approach and examined the Reach Stacker's actual nature, purpose and the restricted premises in which it was used.

Court also clarified that its finding that an ICD is not a ‘public place’ would not restrict a claimant's right to seek compensation under the MV Act if an accident occurs within the ICD involving a ‘regular’ vehicle that ordinarily plies on roads and has been brought into the restricted area by officials of the department or any other person connected with the ICD or its processes.

The Supreme Court ultimately set aside the judgment of the Single Judge of the Delhi High Court and restored the findings of the tribunal. It, however, clarified that if any money had already been paid to Mishra, the same would not be subject to recovery.

Case Title: Container Corporation of India Limited Vs Rishi Ranjan Mishra & Ors 

Bench: Justices Sanjay Karol and N Kotiswar Singh

Date of Judgment: July 29, 2026