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Case Analysis SBI General Insurance Company Limited vs Tulsa Manjhi & Ors 2026 CGHC 26267

Limitation Issue in Motor Accident Claims Pending Supreme Court: Chhattisgarh High Court Directs Tribunal to Proceed but Await Final Adjudication


1. Case Snapshot

Case Name: S.B.I. General Insurance Company Limited vs Tulsa Manjhi & Ors

Citation: CR No.69 of 2026

High Court: High Court of Chhattisgarh at Bilaspur

Bench: Hon'ble Mr. Justice Naresh Kumar Chandravanshi

Date of Judgment: 29th June, 2026

Area of Law: Motor Vehicles Act, Limitation Law, Insurance Law, Civil Procedure


2. Judgment in Brief

The Chhattisgarh High Court disposed of a civil revision petition filed by an insurance company challenging the registration and processing of a motor accident claim application filed after the statutory period of six months. The claim was filed on 01.11.2023 for an accident that occurred on 24.09.2022, i.e., approximately one year and six days after the accident. The insurance company's application under Order VII Rule 11 of the CPC read with Section 3 of the Limitation Act was rejected by the Motor Accidents Claims Tribunal. The High Court noted that the issue of whether the Limitation Act applies to applications under Section 166 of the Motor Vehicles Act is pending consideration before the Supreme Court in ICICI Lombard General Insurance Company Limited v. Ayiti Navaneetha and others and Bhagirathi Dash v. Union of India and another. The Court directed the Claims Tribunal to proceed with the matter but not to pass any final order until the Supreme Court adjudicates the limitation issue. The revision petition was disposed of with these directions.


3. Relevant Facts

The Accident and Claim Application

  • The accident occurred on 24.09.2022.

  • The claimants (respondents no. 1 to 5, 8 & 9) filed a claim application under Section 166 of the Motor Vehicles Act, 1988 before the Motor Accidents Claims Tribunal, Janjir-Champa on 01.11.2023.

  • The claim application was filed after the expiry of six months from the date of the accident, i.e., approximately one year and six days after the accident.

The Insurance Company's Objection

  • The insurance company (applicant herein) filed an application und


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