Jitendra v. Sadiya
Background
In 2016, Jitendra, a 25-year-old labourer, was extracting soybean from a thresher machine attached to a tractor when the tractor's driver reversed it rashly, causing Jitendra's hand to be caught in the machine. He suffered severe injuries and had his hand amputated below the elbow. The Motor Accident Claims Tribunal awarded him roughly Rs. 3.76 lakh in compensation, treating his disability as 20% and his income at a low notional figure; the High Court raised this to about Rs. 6.61 lakh, using a 40% disability figure. Still dissatisfied, Jitendra appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that both the Tribunal and High Court had underestimated Jitendra's loss on two counts. First, relying on precedent, it held that his income should be calculated using the locally applicable minimum wage for unskilled workers (Rs. 6,850/month) rather than a lower, arbitrary figure, since there was no direct evidence of his actual earnings. Second, it held that his "functional" disability, the real-world impact of losing a hand on his ability to work as a labourer, was far more severe than the 40% anatomical disability found below, and raised it to 80%. Recalculating compensation using established precedents for each head (future prospects, medical expenses, pain and suffering, and so on), the Court raised the total award from Rs. 6.61 lakh to approximately Rs. 20.55 lakh.
Lesson Learnt
In disability compensation cases, courts must look beyond the bare medical/anatomical disability percentage and assess how the injury actually affects the victim's real-world capacity to earn a living in their specific occupation, and can use official minimum wage notifications as a fair benchmark for income when no other evidence exists.