Supreme Court enhances motor-accident compensation to ₹36.84 lakh, directs insurer to transfer amount and urges direct bank payments in MACT awards

A bench of Justices J.K. Maheshwari and Rajesh Bindal heard an appeal by Parminder Singh challenging the High Court of Punjab and Haryana’s award in a motor-accident claim. The principal issue related to enhancement of compensation where the appellant, then 21 years old, suffered quadriplegia and was declared 100% permanently disabled after being hit by a car on 03.06.2014.

The Court allowed the appeal and substantially enhanced the compensation, holding that the High Court had underestimated the claimant’s income and failed to grant adequate future prospects and heads of damages. The Court modified the award to a total of ₹36,84,000 and directed respondent No.3, United India Insurance Co. Ltd., to deposit the enhanced amount in the appellant’s bank account within six weeks after verification of account particulars. The Court, in its reasoning, observed: "In our considered view, the income of the appellant has been taken on the lower side, which deserves to be enhanced. Considering the aforesaid credentials of the appellant who was a good sportsman and had certain technical qualification to his credit, in our opinion, taking his income merely at ₹5,600/- per month will not be appropriate. This was even less than the minimum wage for unskilled worker, which at that time was ₹6,447.75 per month w.e.f. 01.03.2014. For semi-skilled worker monthly minimum wage was ₹7,227.75 per month. Hence, we assess the income of the appellant as ₹7,500/- per month. The High Court had rightly applied the multiplier of 18 but failed to grant future prospects under the head ‘Loss of Income’, which in the case of the appellant should be 40%. Hence, income after taking into account future prospects would be ₹10,500/- per month (₹7,500x1.4). The appellant being 100% disabled also deserves to be granted expense towards attendant, which in the case at hand has to be assessed as ₹5,00,000/- in lumpsum and compensation towards special diet is required to be enhanced from ₹25,000/- to ₹1,00,000/-. Considering the significant impact of the disability on the life of appellant, in our view, the amount towards pain and suffering is also required to be enhanced from ₹15,000/- to ₹1,00,000/-. In addition, looking to his condition, ₹2,00,000/- is awarded for future medical expenses and ₹2,00,000/- for loss of marriage prospects." The Court also noted its "concern regarding mode of payment of compensation in motor accident cases" and urged streamlining by "directly transferring the amount in the bank accounts of the claimants."

Background
The appellant, a student aiming to become a veterinary doctor and a state-level volleyball player, suffered grievous injuries resulting in quadriplegia after his motorcycle was struck by a car. He was declared 100% disabled and had incurred medical expenses of ₹2,66,000. The Motor Accident Claims Tribunal (Bathinda) had awarded a conservative total of ₹5,16,000, including ₹2,00,000 for disability. The High Court enhanced the award to ₹15,25,600 by fixing monthly income at ₹5,600 and applying a multiplier of 18, but the claimant sought further enhancement before the Supreme Court.

The Supreme Court reviewed the factual record and accepted that the claimant’s assessed income was below the statutory minimum wages and inadequate given his qualifications and sporting background. The Court applied a revised monthly income of ₹7,500, granted 40% future prospects, applied multiplier 18, and awarded additional heads: attendant charges ₹5,00,000 (lump sum), special diet ₹1,00,000, enhanced pain and suffering ₹1,00,000, future medical expenses ₹2,00,000, loss of marriage prospects ₹2,00,000, and physiotherapy ₹50,000, arriving at ₹36,84,000. The insurer was held liable to pay the enhanced amount, which would carry the same rate of interest as earlier awarded by the High Court. The Court furthermore issued administrative directions encouraging Tribunals to collect bank account particulars at early stages and to order direct electronic transfers in undisputed cases, including measures for fixed deposits where awards concern minors or directives require preservation of a portion of funds. The appeal was allowed and the High Court’s award was modified accordingly.

Case Details:
Case No.: 2025 INSC 361 (Arising out of S.L.P. (C) No. 4484 of 2020)
Case Title: Parminder Singh v. Honey Goyal and Others