Telangana State Level Police Recruitment Board v. Penjarla Vijay Kumar 2025 INSC 1452 - S.14 Motor Vehicles Act - Expiry Of Driving Licence
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Motor Vehicles Act 1988 - Section 14,15 - A Licence no more automatically extends beyond the period of its expiry, as was provided for in the unamended last proviso to Section 14- After the Amendment Act, 2019, from the very next day after the date of expiry, without renewal, the person holding an expired licence is incompetent to drive the vehicles he had such licence for, meaning thereby, that there is a legal disability for driving - The first proviso to sub-section (1) of Section 15, gives a window to a person for renewal of his existing licence, which starts one year prior to the date of the expiry of the licence and continues for one year post-expiry. The theory that once a licence is renewed, even after a gap, the renewal would operate from a back date implying that the licence was continuing and valid even for and during the interregnum cannot be countenanced - (Para 30-33)
Interpretation of Statutes - The deliberate omission by the Legislature cannot be labelled cosmetic. (Para 31)
Case Info
Case Details
- Case name: Telangana State Level Police Recruitment Board v. Penjarla Vijay Kumar & Ors.
- Neutral citation: 2025 INSC 1452
- Coram: Ahsanuddin Amanullah, J.; S. V. N. Bhatti, J.
- Judgment date: December 18, 2025
Caselaws and Citations
- The Divisional Manager, New India Assurance Co. Ltd. v. Shaanabasappa & Ors. (Order dated 24.04.2025), SLP (C) Nos. 19830-19832 of 2022.
- Ram Babu Tiwari v. United India Insurance Co. Ltd., (2008) 8 SCC 165.
- New India Assurance Co. Ltd. v. Suresh Chandra Aggarwal, (2009) 15 SCC 761.
- Ishwar Chandra v. Oriental Insurance Co. Ltd., (2007) 10 SCC 650.
- State of Uttar Pradesh v. Malik Zarid Khalid, (1988) 1 SCC 145.
- Rakesh Kumar Sharma v. State (NCT of Delhi), (2013) 11 SCC 587.
- Sudhir Singh v. State of Uttar Pradesh, (2024) 12 SCC 647.
- A Raja v. D Kumar, 2025 SCC OnLine SC 1033.
Statutes / Laws Referred
- Motor Vehicles Act, 1988:
- Section 3(1) (necessity for driving licence).
- Section 14 (currency of licences) — proviso omitted by 2019 amendment.
- Section 15 (renewal of driving licences) — provisos and sub-sections (1), (3), (4) as amended.
- Sections 19–23 (disqualification/suspension-related provisions referenced).
- Motor Vehicles (Amendment) Act, 2019 (Act 32 of 2019):
- Amendments to Sections 14 and 15; Statement of Objects and Reasons quoted.
