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Section 191: Sale of vehicle in or alteration of vehicle to condition contravening this Act

Motor Vehicles Act • Official Statutory Text & Practice Guide

Statutory Regulation
Legal Standard
Competent Court / Tribunal
Act 1988
Section 190 All 217 Sections of Motor Vehicles Act Section 192

Legal Commentary & Landmark Judgments: Section 191

Section 191 of the Motor Vehicles Act, 1988 historically prohibited the commercial sale and unauthorized structural alteration of motor vehicles in contravention of manufacturing and safety standards, establishing foundational statutory jurisprudence against illegal vehicle modifications prior to its consolidation under Section 182A by the 2019 Amendment.

  • Statutory Ban on Contravention Sales and Structural Alterations: Historically prohibited any person or manufacturer from selling, delivering, or structurally altering a motor vehicle in a manner that breached statutory specifications regarding chassis, dimensions, engine, or safety standards.
  • Consolidation into Section 182A and Chapter VII: Though Section 191 was omitted by the Motor Vehicles (Amendment) Act, 2019 (Act 32 of 2019, s. 73 w.e.f. 1-9-2019), its substantive prohibitions against unauthorized vehicle modification and dealer non-compliance were strengthened and consolidated under Sections 52, 182A, and 182B.
  • Preservation of Statutory Principles on Structural Alteration: Preserves the binding legal principle that vehicle modifications altering original manufacturer specifications registered in Form 20 are void, illegal, and impermissible without RTO certification.
Key Landmark Precedents:
  • Regional Transport Officer v. K.V. Jerry (2019) 17 SCC 726: A landmark Supreme Court judgment holding that Section 52 r/w Chapter VII creates an absolute statutory bar against modifying a motor vehicle in variance with the manufacturer's certified specifications recorded in the registration certificate; no structural alterations to chassis or engines are permissible.
  • Anoop Kumar v. State of Haryana, 2019 SCC OnLine P&H 5218: The High Court held that the omission of Section 191 did not dilute the legislative prohibition against modifying motor vehicles into modified luxury cruisers or altered caravans; illegal alterations remain punishable under the surviving provisions of the Act.
Courtroom Practice & Strategic Litigation Guidance:

In insurance repudiation disputes involving modified vehicles (such as retrofitted flatbeds or modified chassis), insurers can establish a fundamental breach of policy conditions by proving that structural alterations violated manufacturer specifications and Section 52, even after the omission of Section 191.

Section 190 All 217 Sections of Motor Vehicles Act Section 192