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Motor Accident Compensation LawSupreme Court of India

Prakash Chand Sharma v. Rambabu Saini

Civil Appeal · 2025 INSC 180Decided 10 Feb 2025
C.A. No.-002254-002254 - 2025 (arising out of SLP(C) No. 3066 of 2024)
Justice Sanjay Karol · Justice Manmohan

Background

On 23 March 2014, the claimant-appellant was riding his motorcycle back to his village when a Maruti Omni came at him from the wrong side of the road at high speed, leaving him with severe injuries, including to his head, that put him into a comatose state. The Motor Accident Claims Tribunal, Alwar found the other vehicle's driver responsible and awarded roughly Rs. 16.29 lakh in compensation, but assessed his disability at only 50% instead of the 100% found by a duly constituted Medical Board. The Rajasthan High Court partly enhanced this to about Rs. 19.39 lakh but still relied on the 50% disability figure and declined to award attendant charges.

Decision Breakdown

The Supreme Court held that once a duly constituted Medical Board had certified 100% permanent disability (the claimant has no speech, cannot stand or walk, is catheterized, and is fully dependent on others), the Tribunal had no authority to substitute its own lower assessment: its only lawful option, if it doubted the certificate, was to order a fresh medical assessment, which it never did. The Court therefore recalculated the loss of future income and future prospects based on 100% disability, added attendant charges of Rs. 7,80,000 (which had been refused entirely below), and separately enhanced the amount for pain and suffering by Rs. 6,00,000 on top of the sum for physical and mental agony. The final compensation was raised to Rs. 48,69,180, rounded to Rs. 48,70,000, with 7% interest from the date of the claim petition.

Lesson Learnt

Courts and tribunals cannot override the opinion of a properly constituted Medical Board on the extent of a victim's disability without ordering a fresh medical re-assessment; expert medical findings on disability carry significant weight in fixing motor accident compensation.

Prakash Chand Sharma v. Rambabu Saini – Legal Case Shots | LegalAware