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Section 90: Revision

Motor Vehicles Act • Official Statutory Text & Practice Guide

Statutory Regulation
Legal Standard
Competent Court / Tribunal
Act 1988
Section 89 All 217 Sections of Motor Vehicles Act Section 91

Legal Commentary & Landmark Judgments: Section 90

Section 90 of the Motor Vehicles Act, 1988 vests discretionary revisional jurisdiction in the State Transport Appellate Tribunal (STAT) to call for and examine the records of any order passed by the STA or RTA against which no statutory appeal lies, ensuring legality, regularity, and propriety.

  • Revisional Locus and Inherent Prerequisites: The STAT may exercise revisional power either suo motu or upon application made by an aggrieved person against an order of an RTA or STA where no statutory right of appeal is provided under Section 89.
  • Scope of Revisional Scrutiny: Revisional review is confined to examining whether the impugned administrative or quasi-judicial order was illegal, irregular, or improper under Section 90; it is a supervisory jurisdiction not intended for re-evaluating oral or factual evidence.
  • Limitation Window and Natural Justice Safeguards: Application must be filed within thirty days of the date on which the order is made (extendable upon showing sufficient cause); proviso mandates that no adverse order can be passed without affording the affected person a reasonable opportunity of being heard.
Key Landmark Precedents:
  • G.T. Venkataswamy Reddy v. State Transport Authority (2016) 8 SCC 402: The Supreme Court held that the revisional jurisdiction of the STAT under Section 90 is supervisory; the Tribunal cannot act as a court of appeal to re-appreciate findings of fact unless the order of the transport authority is perverse, without jurisdiction, or legally erroneous on the face of the record.
  • Syed Yakoob v. K.S. Radhakrishnan AIR 1964 SC 477: The Constitution Bench established the foundational principles governing quasi-judicial supervisory control, limiting revisional and supervisory interference to patent errors of law that go to the root of the tribunal's jurisdiction.
Courtroom Practice & Strategic Litigation Guidance:

Invoke Section 90 revision when an RTA takes an interlocutory or procedural decision (e.g., granting an interim timetable modification or issuing a route notice) where an appeal under Section 89 is legally barred. Frame the revision memorandum strictly on grounds of jurisdictional excess, violation of natural justice, or procedural irregularity rather than contesting factual road assessments.

Section 89 All 217 Sections of Motor Vehicles Act Section 91