Supreme Court Enhances Motor Accident Compensation to Rs.21.75 Lakh, Awards Rs.3 Lakh Attendant Sum

A bench of Justices K.V. Viswanathan and S.V.N. Bhatti heard an appeal by R. Logeshkumar challenging the Madras High Court’s order dated 20.06.2022 in CMA (MD) No. 3343 of 2014 that had enhanced compensation awarded by the Motor Accidents Claims Tribunal. The appeal concerned the quantum of compensation payable for injuries suffered in a 2012 road accident and the appropriate heads of damages.

The Court allowed the civil appeal in part and further enhanced the compensation to Rs.21,75,681/-, directing interest at 7.5% per annum on the difference from the date of filing the claim petition. The Supreme Court accepted that the Tribunal and the High Court had correctly applied principles governing assessment of future prospects and loss of earnings but held that additional compensation was justified on the facts. The Court observed the guiding principle that tribunals were not confined to the amount claimed and must award “just and fair compensation” based on evidence. The Court, in its reasoning, observed: “In Nagappa v. Gurudayal Singh and others, this Court held that there is no restriction on the Tribunal in awarding compensation exceeding the claimed amount under the Motor Vehicles Act, 1988, and the function of the Tribunal is to award just compensation which is reasonable based on the evidence produced on record. Keeping in view the above ratio, in a given case, the discretion to award compensation in excess of the amount claimed in the petition is based on the evidence on record and for reasons recorded for granting just and fair compensation. Taking note of the loss of monthly income, we deem it appropriate to add 1/3rd of the salary as the future loss of income, totalling to Rs 8,667/-. … We keep in our perspective the age of the Appellant (21 years) during the incident and the requirement of a personal attendant, and award a lump sum of Rs. 3,00,000/-.” The Court also stated, “We wish not to express a view on the entitlement under this head,” in relation to claimed medical expenses introduced before the High Court but not supported by earlier evidence.

Background The dispute arose from a collision on 26 January 2012 when the appellant, then aged 21, riding a two-wheeler, was allegedly struck by a jeep owned by the first respondent and insured by the second respondent. The claimant had sought Rs.15,00,000/- in MCOP No. 2672 of 2013 before the Tribunal. The Tribunal awarded Rs.3,98,017/- (with interest at 7.5%). The claimant appealed for enhancement; the Madras High Court examined the evidence, accepted medical testimony as to grievous injury and functional disability, and enhanced compensation to Rs.14,65,617/-. The High Court fixed the claimant’s monthly income at Rs.6,500/- relying on Syed Sadiq v. Divisional Manager, United India Insurance Co., treating functional disability as 100% and calculating loss of earnings accordingly.

Before the Supreme Court, the appellant sought further enhancement on grounds including addition of future prospects, an attendant allowance, and reimbursement of actual medical expenses of Rs.1,08,000/-. The insurer opposed further enhancement. Relying on precedents including Nagappa v. Gurudayal Singh, the Court allowed a further enhancement: it added one-third to the monthly income (arriving at Rs.8,667/- for future prospects), recalculated loss of earnings to Rs.16,64,064/-, and awarded a lump sum of Rs.3,00,000/- for attendant charges. The Court declined to award the additional medical expenses claim for lack of contemporaneous evidence before the Tribunal. The final award totaled Rs.21,75,681/-, with the difference over amounts already paid to carry interest at 7.5% from the date of filing the claim petition. The Civil Appeal was allowed in part; the deficit court fee was to be deposited before the Tribunal within six weeks. There was no order as to costs.

Case Details: Case No.: 2025 INSC 1392 Case Title: R. LOGESHKUMAR v. P. BALASUBRAMANIAM AND ANOTHER Appearances: For the Petitioner(s): Mr. T. Harish Kumar, Advocate For the Respondent(s): Mr. Vishal Meghwal, Advocate (for the Insurance Company)