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Motor Accident Compensation LawSupreme Court of India

Suresh Jatav v. Sukhendra Singh & Others

Civil Appeal · 2025 INSC 821Decided 14 Jul 2025
Civil Appeal (arising out of SLP (C) No. 20068 of 2022)
Justice K. Vinod Chandran · Justice Sudhanshu Dhulia

Background

The appellant, a skilled mason, suffered a compound leg fracture and a hand fracture in 2002 when a rashly driven bus collided with the auto-rickshaw he was travelling in, leaving him hospitalised for six days and requiring surgery. A doctor certified 35% disability, but the Motor Accident Claims Tribunal reduced this to 25% (reasoning it applied only to the leg) and undervalued his income at Rs. 3,000/month instead of the claimed Rs. 6,000/month, awarding a total of Rs. 1,62,000. The High Court raised the award somewhat on appeal, but the appellant sought further enhancement before the Supreme Court.

Decision Breakdown

The Supreme Court held that a tribunal cannot second-guess an expert doctor's disability assessment without valid reasoning, and since the treating doctor had specifically testified that the appellant could not sit, walk properly, lift weights, or continue his trade as a mason, the full 35% disability (not the Tribunal's reduced 25%) had to be accepted. Relying on precedent (Ramachandrappa v. Royal Sundaram) on wage trends for manual labourers, the Court also accepted the appellant's claimed monthly income of Rs. 6,000 as reasonable for a skilled mason. It recalculated compensation under each head (permanent disability, medical expenses, pain and suffering, loss of income, and other heads) arriving at a substantially enhanced total of Rs. 7,19,480, to be paid within two months after adjusting for amounts already disbursed, with interest running from the date the claim was filed.

Lesson Learnt

In accident compensation cases, tribunals and courts must generally defer to a treating doctor's documented disability assessment unless there is a sound, specific reason to depart from it: an unreasoned downward revision of medical evidence, or an artificially low estimate of a claimant's real income, can and will be corrected on appeal.

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