This judgment arises from a Special Leave Petition (SLP) where the appellant, a victim of a motor vehicle accident, sought enhancement of compensation. Both the Tribunal and the High Court had granted compensation but the appellant contended that his actual income, future prospects, and needs had not been correctly assessed. The Supreme Court considered the evidence, including the appellant's salary, his 100% functional disability, future medical expenses, and costs for an attendant, ultimately enhancing the compensation to ₹52,31,000/-.

1. Background of the Case (Paras 1-3):

The appellant, who was involved in a motor vehicle accident on 16.01.2014, sought enhancement of compensation. A police case was registered, and separate claims were filed by the injured parties and legal heirs of a deceased person. The Tribunal adjudicated the claims in a common award.

2. Tribunal’s Award (Paras 4-8):

The Tribunal assessed the appellant’s income at ₹1,62,420/- per annum based on income tax returns from 2011-12 and awarded ₹20,60,385/- based on 60% disability. The Tribunal also granted ₹50,000/- for mental agony and ₹1,00,000/- for future medical expenses.

3. High Court’s Findings (Paras 9-10):

The High Court modified the Tribunal’s award, increasing the compensation to ₹30,99,873/-, assessing the appellant’s functional disability at 100%. However, the appellant claimed his actual income and future prospects were not properly evaluated.

4. Appellant’s Contentions (Para 10):

The appellant argued that the High Court failed to consider his true monthly income of ₹22,000/-, future medical expenses, attendant needs, and appropriate compensation for mental agony.

5. Insurance Company’s Response (Para 11):

The Insurance Company argued that the High Court’s award was reasonable and exceeded the appellant's original claim of ₹30,00,000/-. They contended no further enhancement was necessary.

6. Supreme Court's Analysis (Paras 12-14.3):

The Supreme Court noted the gap between the income tax returns used by the Tribunal and the date of the accident. The Court assessed the appellant’s income at ₹2,00,000/- per annum and applied a multiplier of 16. It also agreed with the High Court’s assessment of 100% functional disability.

7. Future Prospects and Attendant Costs (Paras 14.3-17):

The Court applied 40% future prospects in line with the Pranay Sethi case and awarded ₹1,00,000/- for future attendant costs, considering the appellant's mental disability and the condition of his mother as his primary caregiver.

8. Compensation for Loss of Marriage Prospects and Pain & Suffering (Paras 18-19):

The Court awarded ₹1,00,000/- each for loss of marriage prospects and for pain and suffering, enhancing the total compensation further.

9. Rejection of Insurance Company’s Argument (Para 20):

The Court dismissed the argument that compensation cannot exceed the claimed amount, citing the duty of the courts to award just compensation regardless of the amount claimed.

10. Final Award (Paras 21-23):

The Supreme Court enhanced the total compensation to ₹52,31,000/- with 6% interest per annum, allowing the appellant’s appeal.

Acts and Sections Discussed:

• Indian Penal Code (IPC): Sections 279 (rash driving), 337 (causing hurt by an act endangering life), and 338 (causing grievous hurt).
• Motor Vehicles Act, 1988: Compensation for accidents.
• Pranay Sethi case: Guidelines for awarding future prospects in motor accident claims.

Ratio Decidendi:

The Court emphasized that while calculating compensation for motor accident victims, it is essential to consider factors like future prospects, 100% functional disability (even if medically assessed as lower), future medical expenses, and attendant costs. The principle of awarding just and reasonable compensation was highlighted, overruling the argument that compensation cannot exceed the claim amount.

Subjecs:

Motor Vehicle Accident, Compensation Enhancement, Functional Disability, Future Prospects

Motor Accidents, Compensation, Supreme Court, Functional Disability, Medical Expenses, Future Prospects, Attendant Cost, Loss of Marriage Prospects, Pain and Suffering