Just Compensation – The Supreme Court reiterated the principle that compensation under the Motor Vehicles Act, 1988, should be "just" and "reasonable," even if it exceeds the amount claimed by the petitioner. This principle was reinforced by the Court’s reference to Meena Devi v. Nunu Chand Mahto, (2023) 1 SCC 204, where it was held that the Tribunal/Court must award compensation based on evidence, regardless of the amount claimed. (Para 9) Permanent Disability – The Claimant-Appellant suffered a 40% permanent disability, which was a significant factor in determining the enhanced compensation. The Tribunal had initially assessed the disability at 10%, but the High Court and Supreme Court revised it to 40%. (Para 7, 10) Future Prospects – The Court applied a 30% increase in the Claimant-Appellant’s income for future prospects, considering his age (51 years) at the time of the accident. This was in line with the precedent set in National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680. (Para 10) Multiplier Method – The Court used a multiplier of 11 to calculate the loss of future earnings, based on the Claimant-Appellant’s age and the principles laid down in Pranay Sethi. (Para 10) Medical Expenses and Other Heads – The Court awarded compensation under various heads, including medical expenses, attendant charges, special diet, transportation, pain and suffering, and loss of income during treatment. The total compensation awarded was Rs. 17,82,825/-, significantly higher than the amounts awarded by the Tribunal (Rs. 6,17,515/-) and the High Court (Rs. 6,77,515/-). (Para 10)

The Supreme Court allowed the appeal and enhanced the compensation to Rs. 17,82,825/-, modifying the awards of both the Tribunal and the High Court. The Court emphasized that compensation must be just and reasonable, based on the evidence and principles laid down in previous judgments. (Para 10, 11)

Major Acts:

• Motor Vehicles Act, 1988 – The primary legislation under which the compensation claim was filed.

• Indian Penal Code, 1860 (IPC) – Sections 279, 337, and 338 were invoked in the FIR related to the accident.

Issues:

1. Whether the compensation awarded by the Tribunal and High Court was just and fair under the Motor Vehicles Act, 1988? – The Supreme Court held that the compensation should be based on the evidence and principles of just compensation, even if it exceeds the claimed amount. (Para 9)

2. What is the correct assessment of permanent disability and its impact on compensation? – The Court revised the permanent disability assessment from 10% to 40%, significantly impacting the final compensation amount. (Para 7, 10)

3. How should future prospects and multiplier be applied in calculating compensation? – The Court applied a 30% increase for future prospects and a multiplier of 11, in line with established precedents. (Para 10)

Submissions/Arguments:

• The Claimant-Appellant argued that the compensation awarded by the Tribunal and High Court was inadequate, especially considering his 40% permanent disability and the extensive medical expenses incurred. (Para 7)

• The Respondent (Insurance Company) did not contest the additional consolidated sum granted by the High Court, but the Supreme Court emphasized that consent does not override the principle of just compensation. (Para 9)

Ratio:

• Just Compensation – The Court held that the objective of compensation under the Motor Vehicles Act, 1988, is to ensure that the aggrieved party receives just and fair compensation, which may exceed the amount claimed. (Para 9)

• Future Prospects and Multiplier – The Court applied a 30% increase for future prospects and a multiplier of 11, in line with the principles established in Pranay Sethi. (Para 10)

• Permanent Disability – The Court revised the permanent disability assessment from 10% to 40%, significantly impacting the final compensation amount. (Para 10)

Subjects:

• Motor Vehicles Act, 1988 – Compensation – Just and Fair – Permanent Disability – Future Prospects – Multiplier Method – Medical Expenses – Pain and Suffering – Loss of Income.