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Issues: Whether the expression "public place" in Chapter VIII of the Motor Vehicles Act, 1939 includes private premises to which members of the public have access, whether free or controlled.
Analysis: Section 2(24) defines "public place" broadly as a road, street, way or other place to which the public have a right of access. The expression was construed in the light of its plain language, the object of the Act, and prior decisions distinguishing between "right of access" and "access as of right". A place need not be public property, and even restricted or regulated access does not prevent it from falling within the definition if members of the public can access it. The beneficial nature of the legislation also supported a wider construction.
Conclusion: The expression "public place" covers all places, including private ownership premises, where members of the public have access whether free or controlled in any manner whatsoever.
Ratio Decidendi: For the purpose of Section 2(24) of the Motor Vehicles Act, 1939, a place is a public place if it is accessible to members of the public, even where such access is regulated, restricted or controlled.