Registered owner liability under motor accident law continues until transfer is recorded, despite an unregistered sale.

For motor accident compensation under the Motor Vehicles Act, 1988, the person whose name remains in the registration certificate is treated as the owner under Section 2(30), subject only to the statutory exceptions for a minor, hire-purchase, lease, or hypothecation. Section 50 governs transfer procedure and reporting, but an unregistered sale does not by itself shift liability away from the registered owner until the record is updated. Earlier law under the Motor Vehicles Act, 1939 was distinguished because the later definition was a deliberate departure. Requisitioned vehicle and hypothecation cases were also distinguished as turning on possession and control in those specific contexts.

---

---

Issues: Whether, for the purposes of compensation under the Motor Vehicles Act, 1988, the person whose name continued in the registration certificate remained the owner and liable despite an unregistered sale, and whether failure to report transfer under Section 50 displaced that liability.

Analysis: The expression "owner" in Section 2(30) was held to mean the person in whose name the vehicle stands registered, subject only to the statutory exceptions for a minor, hire-purchase, lease, or hypothecation. The earlier definition in Section 2(19) of the Motor Vehicles Act, 1939 was materially different, and the later enactment was read as a deliberate departure to fix responsibility on the registered owner. Section 50 was treated as prescribing the procedure for transfer and reporting, but not as shifting liability away from the registered owner until the records are updated. The decisions dealing with requisitioned vehicles and hypothecation were distinguished on the ground that they turned on possession and control in those specific situations, not on a voluntary sale where the transfer was not reflected in the register.

Conclusion: The registered owner remained liable for compensation, and the High Court erred in absolving him and fastening liability on the appellant.

Ratio Decidendi: For motor accident claims under the Motor Vehicles Act, 1988, the person shown as the registered owner is liable as owner unless a statutory exception under Section 2(30) applies, and an unrecorded transfer does not by itself shift that liability.

---