Supreme Court enhances motor-accident award to Rs.35.92 lakh, fixes multiplier at 18 and adopts Rs.9,000 monthly income

A bench of Justices Sudhanshu Dhulia and K. Vinod Chandran heard an appeal arising from a motor-accident compensation claim by a 25‑year‑old victim who became bed‑ridden after a truck crash; the appeal challenged the quantum awarded by the High Court and the Tribunal. The core issue before the Court was the correct assessment of monthly income, multiplier and just compensation in view of precedents relating to assessment of loss of future earnings.

The Court allowed the appeal in part and enhanced the award. It held that, applying the principles in Ramachandrappa and National Insurance Co. Ltd. v. Pranay Sethi, an incremental adjustment to historic assessed incomes was warranted and the multiplier for a 25‑year‑old was 18. The Court noted that the claimant had asserted monthly income of Rs.9,000 and that figure could "be safely adopted". The Court directed payment of the enhanced amount with interest at 8% per annum within two months and permitted the appellant or authorised representatives to provide account details for online disbursement. The Court, in its reasoning, observed: "Ramachandrappa ... determined an income of Rs.4,500/- per month in the year 2004 for a coolie. A Constitution Bench in National Insurance Company Limited vs. Pranay Sethi and Others found that there would be an incremental increase in the income which according to us would be reasonable if fixed at Rs.500/- per month for every successive year. In the present case, the accident occurred in the year 2015, 11 years after 2004 and going by the principles stated in the afore‑cited decisions the appellant, an unskilled worker would be entitled to claim monthly income of Rs.10,000/-. In the present case, the claimant has asserted an income of Rs.9,000/- which can be safely adopted. The multiplier in the case of a 25 year old as held in Pranay Sethi would be 18 and not 17 as taken by the High Court."

Background: The appellant was a 25‑year‑old who, as the judgment set out, "has become completely bed ridden due to an accident caused when he was travelling in the truck of his employer, which crashed with another vehicle." He claimed negligence of the truck driver, asserted annual income of Rs.9,000, and sought total compensation of Rs.68,44,000 including past and future medical expense and lifelong care. The Motor Accident Claims Tribunal awarded Rs.16,00,000, reasoning that interest from the sum would provide for future needs. The Insurance Company had contended that the policy did not cover passengers in a goods vehicle, but the Tribunal found the claimant to be an employee of the vehicle owner; as the insurer did not challenge that finding by way of appeal, the Court declined to entertain that contention in the present enhancement proceedings.

On appeal to the High Court, the monthly income accepted by the Tribunal (noted as Rs.4,500 in earlier precedent) was increased to Rs.6,000, 40% was added for future prospects, and medical bills of Rs.2,70,000 were allowed. The High Court assessed functional disability at 100% and granted a consolidated sum of Rs.6,00,000 for pain and suffering and related heads, arriving at Rs.25,83,600 in total. Before this Court, applying the principles in Ramachandrappa and Pranay Sethi, the Supreme Court held that upward revision to reflect cumulative increments was appropriate; it adopted the claimant’s asserted monthly income of Rs.9,000 (noting a reasonable entitlement to Rs.10,000 by calculation) and fixed the multiplier at 18 for a 25‑year‑old. The Court calculated the award as follows: loss of future income Rs.27,21,600; medical expenses Rs.2,70,000; pain and suffering etc. Rs.6,00,000; total Rs.35,91,600. After deduction of amounts already paid, the balance was to be disbursed with 8% interest per annum within two months into accounts to be furnished by the appellant or his representatives. The appeal was allowed with those modifications and pending applications were disposed of.

Case Details: Case No.: Special Leave Petition (C) No. 26999 of 2023 (2025 INSC 673) Case Title: Shaikh Sadik Shaikh Rafique v. Reliance General Insurance Company Limited & Ors. Appearances: For the Petitioner(s): [Not indicated in the judgment] For the Respondent(s): [Not indicated in the judgment]