The appellant relied on several decisions of the Supreme Court and various High Courts dealing with Comprehensive/Package insurance policies.The Delhi High Court has held that claims arising solely from the contractual terms of a personal accident cover under a Comprehensive/Package motor insurance policy cannot be adjudicated by the Motor Accident Claims Tribunal (MACT). The Court ruled that where compensation is claimed under a personal accident cover rather than the statutory liability provisions of the Motor Vehicles Act, the claimant must pursue the remedy before the appropriate forum, such as a consumer forum or civil court.Justice Anish Dayal dismissed an appeal challenging the rejection of a compensation claim by the MACT, holding that the Tribunal's jurisdiction is confined to statutory claims under the Motor Vehicles Act and cannot be expanded to determine purely contractual disputes arising under an insurance policy.Emphasising the limits of the Tribunal's jurisdiction, the Court observed that extending the MACT's powers to adjudicate contractual insurance disputes would amount to "expanding the motor accidents jurisprudence to an illogical extremity."BackgroundThe appeal arose from a fatal road accident involving an Innova car driven by Udey Singh alias Uday Jit Singh. According to the claim, an unidentified truck struck the rear of the vehicle, causing it to collide with another car before crashing into a wall. Udey Singh died in the accident, while the offending truck could not be traced, resulting in the case being treated as a hit-and-run incident.The vehicle was registered in the name of Amarjit Singh, the deceased's father, and was insured under a Comprehensive/Package policy issued by the insurer. Following the accident, the deceased's mother filed a claim petition before the Motor Accident Claims Tribunal under Section 166 of the Motor Vehicles Act, seeking compensation from the insurer. She argued that although the deceased was driving the vehicle, he should be treated as an occupant or third party covered under the insurance policy.The Motor Accident Claims Tribunal dismissed the claim, relying on earlier Supreme Court decisions holding that claims based on contractual liability under an insurance policy fall outside the Tribunal's jurisdiction. It held that while the claimant was free to pursue an appropriate contractual remedy, such a claim could not be entertained by the MACT.Aggrieved by that decision, the claimant approached the Delhi High Court.Parties' SubmissionsThe appellant argued that the Tribunal had failed to distinguish between an "Act Only Policy" and a "Comprehensive/Package Policy." It was submitted that the vehicle was insured under a Comprehensive/Package policy providing personal accident cover in addition to third-party insurance. Relying on several Supreme Court and High Court decisions, the appellant argued that where additional premium had been paid, the insurance cover extended beyond the minimum statutory requirements. Since the deceased was driving the insured vehicle with the owner's permission, it was argued that he should be treated as an occupant or third party entitled to compensation under the policy.The appellant also argued that the principle that a borrower steps into the shoes of the owner applies only to claims under Section 163-A of the Motor Vehicles Act and not to claims under Section 166. It was submitted that denying compensation to a permissive driver under a Comprehensive/Package policy would defeat the beneficial object of the Motor Vehicles Act.The insurer, supported by the Amicus Curiae appointed by the Court, opposed the appeal. It argued that the deceased was neither the owner-driver covered by the personal accident clause nor a third party for the purposes of a statutory claim before the MACT. The respondents argued that any entitlement flowing from the personal accident cover was contractual in nature and therefore enforceable only before the appropriate civil or consumer forum, not before the Tribunal constituted under the Motor Vehicles Act. They further argued that since the offending vehicle remained untraced, negligence could not be established against it in a claim under Section 166.The Amicus Curiae also submitted that specialised tribunals such as the MACT should not be permitted to assume jurisdiction over disputes falling outside the statutory scheme of the Motor Vehicles Act. Expanding the Tribunal's jurisdiction to adjudicate contractual insurance disputes, it was argued, would dilute the purpose for which the MACT was established.The principal question before the High Court was whether a claim based on the personal accident cover contained in a Comprehensive/Package insurance policy could be adjudicated by the Motor Accident Claims Tribunal, or whether such a claim, being contractual in nature, lay outside the Tribunal's statutory jurisdiction.Court: MACT Can Award Compensation Only for Statutory LiabilityExamining the statutory scheme of the Motor Vehicles Act, the High Court observed that claims before the Motor Accident Claims Tribunal are founded on statutory liability arising from the negligence of a tortfeasor. It said the Tribunal's jurisdiction extends to claims contemplated under the Act and cannot be enlarged to determine disputes arising purely out of contractual obligations contained in an insurance policy.The Court explained that a victim of a motor accident may pursue compensation against the owner or insurer of an offending vehicle where liability is established under the Motor Vehicles Act. However, where the claim is based solely on benefits flowing from a personal accident cover purchased under an insurance policy, the dispute falls within the realm of contract rather than statutory liability.The High Court noted that the claim had been filed under Section 166 of the Motor Vehicles Act, which necessarily requires proof of negligence.Since the truck responsible for the accident could not be identified, the appellant was unable to establish negligence on the part of the offending vehicle. The Court observed that the only other possible allegation of negligence would necessarily be against the deceased himself, who was driving the insured vehicle.The Court observed:"Claim made by a third party is, therefore, inextricably intertwined with proof of negligence of the driver of the offending vehicle."The Court said that permitting the legal representatives of the deceased driver to maintain a claim under Section 166 in such circumstances would lead to an illogical result, as it would effectively require them to establish negligence against the deceased himself.Personal Accident Cover Gives Rise to Contractual, Not Statutory, RightsThe High Court then distinguished between statutory liability under the Motor Vehicles Act and contractual liability arising under an insurance policy.It observed that while the owner had purchased a Comprehensive/Package policy by paying an additional premium for personal accident cover, that cover was based entirely on the terms of the insurance contract and not on any statutory obligation imposed by the Motor Vehicles Act.The Court said:"The claim made under the insurance policy is not a claim arising out of negligence of a party, but merely a claim where the risk of bodily injury or death of owner-driver is covered by the Insurance Company. This takes the claim into a purely contractual arena."Accordingly, it held that such claims must be examined by applying the terms and conditions of the insurance contract rather than the provisions governing compensation under the Motor Vehicles Act. Tribunal Cannot Exercise Jurisdiction Beyond the Motor Vehicles ActThe Court agreed with the submissions of the Amicus Curiae that specialised tribunals should not assume jurisdiction beyond what the governing statute expressly confers.Referring to the concept of "fetishizing specialised jurisdiction" advanced during the hearing, the Court observed that expanding the MACT's jurisdiction to decide contractual insurance disputes would undermine the statutory framework governing specialised tribunals. It held that a Tribunal constituted under the Motor Vehicles Act cannot adjudicate contractual disputes merely because they arise from a motor insurance policy. Those disputes must be resolved before the forum competent to interpret and enforce contractual rights.The appellant relied on several decisions of the Supreme Court and various High Courts dealing with Comprehensive/Package insurance policies.The High Court held that those authorities did not advance the appellant's case because they arose in materially different factual situations. Some involved occupants who were not driving the vehicle, while others concerned claims under different provisions of the Motor Vehicles Act or addressed only the extent of insurance coverage without considering the jurisdiction of the MACT to adjudicate contractual disputes.The Court instead found support in decisions that recognised the distinction between statutory liability under the Motor Vehicles Act and contractual liability arising from additional insurance coverage. It reiterated that while a contractual claim may survive under the insurance policy, its enforcement does not lie before the Motor Accident Claims Tribunal.Having concluded that the claim was contractual in nature, the High Court clarified that the appellant was not without a remedy. It observed that the claimant could approach the insurer under the personal accident cover contained in the Comprehensive/Package policy. If the insurer rejected the claim, the claimant would be free to pursue the available remedies before the consumer forum or any other competent forum in accordance with law.Holding that the Motor Accident Claims Tribunal lacked jurisdiction to adjudicate a claim founded solely on contractual rights under a personal accident insurance cover, the High Court upheld the dismissal of the claim petition.The Court concluded that extending the Tribunal's jurisdiction to such disputes would blur the distinction between statutory compensation under the Motor Vehicles Act and contractual insurance claims.Observing that doing so would amount to "expanding the motor accidents jurisprudence to an illogical extremity," the Court dismissed the appeal while leaving it open to the claimant to pursue an appropriate contractual remedy before the competent forum.MAC.APP. 532/2025SIMBAL SINGH vs AMARJIT SINGH & ANR.Date of Decision: 01.07.2026For Appellant: Mr. Varun Sarin, Ms. Parul Dutta, Advocates.For Respondent: Dr. Amit George, Amicus Curiae with Mr. Dushyant Kishan Kaul, Advocates for respondent no.1 Mr. Sameer Nandwani, Advocate for respondent no.2.(The author of this article, Vatsal Chandra is a Delhi-based Advocate practicing before the courts of Delhi NCR.)