Light motor vehicle licence covers light goods vehicle use, so insurer recovery rights were not sustained.

A valid licence for a light motor vehicle authorises the driver to operate a light goods vehicle under the Motor Vehicles Act, 1988, and the absence of a separate endorsement for commercial use does not by itself establish breach of policy condition. Applying prior authority on the scope of light motor vehicle licences, the SC rejected the insurer's recovery claim because the alleged policy breach was not made out. Recovery rights were therefore denied in favour of the insured parties.

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Issues: Whether an insurer is entitled to recovery rights on the ground of breach of the insurance policy when the driver held a licence to drive a light motor vehicle but had no separate endorsement for driving a light goods vehicle.

Analysis: The governing definitions under the Motor Vehicles Act, 1988 were applied to determine the scope of a light motor vehicle and the effect of a licence held for that class. The Court relied on prior authority holding that a valid licence for a light motor vehicle authorises driving a light goods vehicle as well, and also recognised that the absence of an endorsement for using such a vehicle as commercial transport does not, by itself, establish a breach of policy condition. On that basis, the insurer's claim for recovery rights could not be sustained.

Conclusion: The insurer was not entitled to recovery rights, and the finding of breach of policy condition was rejected in favour of the appellants.

Ratio Decidendi: A driver holding a valid licence for a light motor vehicle is authorised to drive a light goods vehicle, and the insurer cannot claim recovery rights merely because no separate endorsement for that vehicle type or commercial use was obtained.

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