Andhra Pradesh High Court Rules Excavator Qualifies as ‘Motor Vehicle’ Under Motor Vehicles Act, 1988

In a significant and far-reaching judgment, the Andhra Pradesh High Court has ruled that an excavator, despite its specialized industrial use, squarely falls within the definition of a "motor vehicle" under Section 2(28) of the Motor Vehicles Act, 1988. Delivered on May 9, 2025, by Justice V.R.K. Krupa Sagar, this verdict arises from a tragic incident involving the negligent operation of an excavator that fatally ran over a man sleeping by the roadside. The central question before the Court was whether such a machine, typically associated with construction and often operated off-road, can be legally recognized as a "motor vehicle" within the ambit of the Act, thereby invoking liability under motor accident compensation provisions.

The Court emphatically held that the excavator, being a mechanically propelled vehicle that was used in a public space, satisfies the definitional criteria under the Act. The judgment delves into the nuances of Section 2(28), which includes any vehicle adapted for use upon roads, regardless of whether propulsion is internal or external, and explicitly excludes vehicles on fixed rails, those used only in factories or enclosed premises, and vehicles with engines under 25cc with less than four wheels.

The excavator in question, which was not confined to an enclosed space, not on fixed rails, and possessed engine capacity well beyond the minimal threshold, therefore does not fall within the exclusionary clauses. The Court noted that at the time of the incident, the excavator was not being used solely within a factory or private premises but was operating in a public area, making it subject to the regulatory framework governing public road use. In doing so, the Court aligned with the beneficial object of the Motor Vehicles Act, which seeks to ensure compensation for accident victims through a broad, welfare-centric interpretation of the law.

The ruling also underscores the judicial commitment to upholding the rights of victims and affixing accountability on vehicle owners and insurers, particularly when heavy machinery like excavators causes harm outside their traditional work environments.

The case also sets a precedent by reaffirming that insurance companies cannot evade liability by narrowly interpreting the term ‘motor vehicle’ to exclude such machinery. Furthermore, by drawing on precedents like Chairman, R.S.R.T.C. v. Santosh (2013), the Court reinforced the principle that legal classifications should not shield negligent actors from responsibility when their actions cause death or injury in public spaces.

With this verdict, the Court has expanded the interpretative scope of motor vehicle liability, reaffirming that function, usage, and location of operation—rather than just design or classification—are critical in determining legal obligations under the Act.

This judgment thus carries major implications for the insurance and construction sectors, stressing the need for comprehensive insurance coverage and heightened regulatory compliance when deploying such machinery beyond controlled industrial zones.