Supreme Court Enhances Compensation for Amputee in Motor Accident Case

The Supreme Court of India has significantly enhanced the compensation awarded to a motor accident victim, increasing the amount from Rs. 6.7 lakh to Rs. 28.93 lakh. The Court ruled that the victim, who suffered a 90% disability due to amputation, was entitled to higher compensation considering his loss of earning capacity and future prospects.

Background of the Case

The case arose from an accident on April 3, 2018, when the claimant-appellant, Sanjay Rajpoot, a 23-year-old, was traveling on his motorcycle in Jhansi, Uttar Pradesh. A rashly driven bus, bearing registration number DL-1PB-9197, collided with him, resulting in severe injuries. His right leg had to be amputated above the knee, and he also suffered major injuries to his right hand.

An FIR (No. 57/2018) was filed against the driver of the offending vehicle at Bandagon Police Station under Sections 279, 337, 338, and 427 of the Indian Penal Code (IPC). Subsequently, Sanjay Rajpoot filed a compensation claim before the Motor Accident Claims Tribunal (MACT), seeking Rs. 67,00,000/- as damages, citing his monthly income of Rs. 25,000 from running a coaching center and working as an accountant.

Lower Court Rulings

The MACT ruled that the insurance company was liable to pay compensation but assessed the claimant’s notional income at only Rs. 6,000 per month. The tribunal awarded Rs. 6,70,000/- at an interest rate of 6%, based on a 50% disability assessment.

Dissatisfied with the compensation amount, the claimant appealed to the High Court of Allahabad, which increased the award to Rs. 10,10,004/-. The High Court granted an additional Rs. 1,00,000 for pain and suffering and added 40% under the head of future prospects.

Still dissatisfied, the claimant approached the Supreme Court, seeking an appropriate assessment of his earning capacity and functional disability.

Key Legal Issues

Whether the assessment of the claimant’s disability by the lower courts was correct.
Whether the determination of the claimant’s income was fair.
Whether future prospects should be considered for a self-employed individual in a compensation claim.
Whether additional compensation should be granted for pain and suffering, loss of marriage prospects, and assistive devices.

Arguments by the Appellant

The appellant argued:

The lower courts erroneously assessed his disability at 50%, whereas the loss of his right leg and severe injuries to his right hand resulted in 90% functional disability.
As a self-employed person running a coaching center and working as an accountant, his actual income was Rs. 25,000 per month, which should have been considered instead of the notional Rs. 6,000.
The loss of his ability to move around freely significantly affected his ability to work.
The award should include compensation for loss of marriage prospects and assistive devices such as prosthetic limbs.

“The functional disability of the appellant must be assessed in relation to his ability to earn, not merely his medical impairment.”

Arguments by the Respondents

The insurance company and other respondents countered:

The lower courts had correctly applied the standard assessment for disability.
The claimant did not provide documentary proof of his monthly income, justifying the tribunal’s decision to use notional income.
The High Court had already enhanced the compensation with additional amounts for pain and suffering and future prospects.
Additional compensation should not be granted beyond what the High Court had already ruled.

“The determination of compensation must be fair, but it cannot be speculative.”

Supreme Court’s Observations

The Supreme Court examined the medical and financial aspects of the case and made the following key observations:

The lower courts failed to adequately assess the impact of amputation on the appellant’s earning capacity. The loss of a leg for a self-employed person severely restricts mobility and economic opportunities.
The appellant’s disability should be assessed as 90% for the purpose of calculating loss of earnings.
Given the appellant’s age (22 years at the time of the accident), a multiplier of 18 should be applied.
The compensation must include amounts for pain and suffering, assistive devices, and loss of marriage prospects.

“For a self-employed person, functional disability must be assessed in relation to the nature of their work. The loss of a leg substantially reduces the appellant’s ability to earn and move independently.”

Final Compensation Calculation

Based on the Supreme Court’s analysis, the revised compensation was calculated as follows:

Monthly Income: Rs. 6,000
Annual Income: Rs. 72,000
Future Prospects (40%): Rs. 28,800
Total Income per Year: Rs. 1,00,800
Multiplier (18): Rs. 18,14,400
Permanent Disability (90%): Rs. 16,32,960
Medical Expenses: Rs. 53,204
Attendant Charges: Rs. 1,08,000
Loss of Marriage Prospect: Rs. 2,00,000
Special Diet & Transportation: Rs. 1,00,000
Pain and Suffering: Rs. 3,00,000
Assistive Device (Prosthetic Limb): Rs. 5,00,000
Total Compensation: Rs. 28,93,494

Final Judgment

The Supreme Court ruled:

“The compensation is enhanced to Rs. 28,93,494. The insurance company is directed to pay the revised amount within one month, along with interest as awarded by the Tribunal.”

The judgment also clarified that interest should be paid as per the rates determined by the Tribunal.

Impact of the Judgment

This ruling sets an important precedent:

Recognizes that functional disability must be assessed concerning an individual’s occupation and mobility.
Confirms that future prospects apply even to self-employed individuals in motor accident claims.
Ensures that compensation includes provisions for assistive devices and loss of marriage prospects.
Prevents under-assessment of claims for serious disabilities that impact earning capacity.

By significantly enhancing the compensation, the Supreme Court has reinforced the principle that accident victims must be fairly compensated for their loss of earning potential and quality of life.

Petitioner Name: Sanjay Rajpoot.
Respondent Name: Ram Singh & Ors..
Judgment By: Justice Sanjay Karol, Justice Prashant Kumar Mishra.
Place Of Incident: Jhansi, Uttar Pradesh.
Judgment Date: 11-02-2025.

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