Is a Reach Stacker a ‘Motor Vehicle’? Supreme Court Says No, and an ICD Is Not a Public Place

Case at a Glance

The Supreme Court has held that a Reach Stacker used to handle containers inside the Inland Container Depot (ICD) at Tughlakabad is not a “motor vehicle” under Section 2(28) of the Motor Vehicles Act, 1988, and that the ICD’s internal roads are not a “public place” under Section 2(34). It set aside a Delhi High Court judgment and restored the Tribunal’s view, while directing that any amount already paid to the injured worker shall not be recovered.

On 5 September 2013, respondent no. 1 was at the ICD, Tughlakabad, New Delhi, when a Reach Stacker hit him and ran over his pelvic region. After several surgeries his right leg was amputated. He filed a claim petition under Section 166 of the Motor Vehicles Act seeking Rs 75 lakh, pleading 100% functional disability.

On 9 January 2018 the Motor Accident Claims Tribunal at Saket allowed the insurer’s (New India Assurance) application under Order VII Rule 11 CPC. On 5 September 2019 a Single Judge of the Delhi High Court set that order aside and held that a Reach Stacker is a motor vehicle. Container Corporation of India appealed.

The Key Question Before the Court

Can a claim under the Motor Vehicles Act lie for an accident caused by a Reach Stacker operating inside a custom-bonded Inland Container Depot?

Public Place, Special-Type Vehicles and Registration

Relying on Tarachand Logistic Solutions Ltd. v. State of A.P., (2025) 08 SC CK 0201, the Court held that the ICD is a custom-bonded area under Section 7 of the Customs Act, 1962, where access is limited to authorised persons, so its internal roads are not a “public place”. Reviewing Bolani Ores, (1974) 09 SC CK 0027, Goodyear India and Ultratech Cement, (2026) 01 SC CK 1859, among others, it noted that “A vehicle which merely moves from one place to another need not necessarily be a motor vehicle”.

Following Ultratech, the Court found that the Reach Stacker falls within the exclusion in Section 2(28) for vehicles of a special type adapted for use only in a factory or other enclosed premises: it is used only in enclosed, notified areas, exceeds permitted weight limits, is dismantled for transport and lacks general road-safety features. It added that such a vehicle cannot be registered under Section 39 where the transport authority treats it as not a motor vehicle.

What the Court Actually Held

• The appeal was allowed and the Delhi High Court judgment of 5 September 2019 was set aside.
• The Tribunal’s findings were restored.
• Any amount already paid to the injured respondent is not to be recovered.
• Compensation under the Act remains available if a regular road vehicle brought into the ICD causes an accident there.

Why This Judgment Matters

• It clarifies when port and depot machinery falls outside the Motor Vehicles Act.
• It explains the ‘public place’ test for restricted-access customs areas.
• It guides claimants injured in industrial or depot premises on choosing the right forum.

What Should Advocates Take Away From the Judgment?

For Claimants’ Counsel

• Check whether the vehicle is a special-type machine confined to enclosed premises before filing under Section 166.
• Look at the place of accident: restricted customs areas may not be ‘public places’.
• Consider other remedies (such as employee compensation or civil claims) where the MV Act may not apply.

For Insurers and Operators

• Weight, transport method, safety features and area of use are relevant to the Section 2(28) exclusion.
• Accidents inside an ICD involving ordinary road vehicles can still attract MV Act liability.

Key Takeaways

Frequently Asked Questions

The MV Act claim failed, but the Court directed that any amount already paid to him shall not be recovered.

No. The Court said compensation remains available if a regular road vehicle brought into the ICD causes an accident there.

It followed Ultratech Cement on the exclusion for special-type vehicles used only in enclosed premises.

Conclusion