Requisitioned vehicle liability turns on actual control, so the State rather than the registered owner bears accident compensation responsibility.

Where a motor vehicle is requisitioned by the State and placed under the effective control of a statutory authority, liability for accident compensation follows actual control rather than the registered owner's bare title under the Motor Vehicles Act. The Court distinguished authorities dealing with voluntary transfer, consent-based use, and leasing, because requisition is an involuntary statutory taking. On those facts, the State in control of the requisitioned vehicle was liable, the registered owner was not liable, and the insurer could not be fastened with liability.

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Issues: Whether, when a motor vehicle is requisitioned by the State and remains under the control of a statutory authority, liability to pay compensation for an accident involving that vehicle falls on the registered owner, the State, or the insurer.

Analysis: The statutory definition of "owner" under the Motor Vehicles Act was read in the context of the scheme of the Act and the factual situation in which the vehicle had been requisitioned by the State for election duty. During requisition, the registered owner retained title only in a legal sense and had no effective control over the use or operation of the vehicle. The ordinary rule of liability based on ownership or insurance was therefore not ative in the same way as where the vehicle remained under the owner's control. The earlier authorities dealing with consent-based use, transfer, or leasing of vehicles were distinguished because requisition is an involuntary statutory taking and not a voluntary handing over of control.

Conclusion: The State, as the authority in control of the requisitioned vehicle, was liable to pay compensation and the registered owner was not liable; consequently, the insurer could not be fastened with liability on the facts of the case.

Ratio Decidendi: Where a requisitioned vehicle is under the effective control of the State, the statutory definition of owner must yield to context, and liability for accident compensation attaches to the party exercising actual control rather than the registered owner.

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