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Parminder Singh v. Honey Goyal and Others

Civil Appeal · 2025 INSC 361Decided 18 Mar 2025
C.A. No.-004299-004299 - 2025 (Arising out of S.L.P. (C) No. 4484 of 2020)
Justice J.K. Maheshwari · Justice Rajesh Bindal

Background

The appellant, a 21-year-old aspiring veterinary doctor and state-level volleyball player, was hit by a car while riding his motorcycle in 2014 and suffered quadriplegia, leaving him 100% permanently disabled. The Motor Accident Claims Tribunal at Bathinda awarded him about ₹5.16 lakh in compensation, which the Punjab and Haryana High Court enhanced to about ₹15.26 lakh by raising only the "loss of income" head (assessed on a monthly income of ₹5,600). Still dissatisfied, he approached the Supreme Court seeking further enhancement, arguing his income was undervalued and that future prospects and other heads had been ignored.

Decision Breakdown

The Supreme Court held that valuing the appellant's income at ₹5,600 per month, below even the minimum wage for an unskilled worker at the time, was too low given his sporting achievements and technical qualifications, and re-fixed it at ₹7,500 per month. It upheld the multiplier of 18 used by the High Court but added 40% for future prospects (since the disability struck him at a young age), and separately enhanced compensation for attendant charges (₹5,00,000), special diet, pain and suffering, future medical expenses, loss of marriage prospects, and physiotherapy expenses. Total compensation was raised to ₹36,84,000, payable with interest by the insurer within six weeks, directly into the appellant's bank account. The Court also used the case as an occasion to issue system-wide directions for insurers/Tribunals to transfer awarded compensation directly into claimants' bank accounts, rather than routing it through court deposit, to prevent delay and loss of interest.

Lesson Learnt

In assessing compensation for permanently disabling accidents, courts must look beyond a claimant's documented income and account for genuine future earning potential, future prospects, and the real, lifelong costs of disability (attendant care, special diet, medical needs), and going forward, motor accident compensation should be transferred directly to claimants' bank accounts rather than left to languish in court deposits.

Official source (sci.gov.in)View Judgment (PDF)

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