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Prahlad Sahai v. Haryana Roadways

Civil Appeal · 2026 INSC 396Decided 21 Apr 2026
C.A. No.-004642-004642 - 2026
Justice J.B. Pardiwala · Justice K.V. Viswanathan · Justice Nongmeikapam Kotiswar Singh

Background

The appellant's right leg had to be amputated below the knee after a bus belonging to Haryana Roadways struck the motorcycle he was riding in Jaipur in 2007. The Motor Accident Claims Tribunal awarded him about Rs. 8.73 lakh in compensation, which the Rajasthan High Court enhanced to about Rs. 13.02 lakh. The appellant, a heavy-vehicle driver by occupation who could no longer drive after the amputation, appealed to the Supreme Court seeking a fair method of computing compensation for a prosthetic limb and higher awards under other heads such as loss of future income.

Decision Breakdown

The Supreme Court examined the principles for computing compensation for a prosthetic limb, emphasizing (quoting English case law) how deeply personal and life-altering such a device is for an amputee. It accepted the appellant's claimed monthly income of Rs. 6,000 (rejecting the Tribunal/High Court's lower estimate of Rs. 4,500) even without full documentary proof, and computed 100% functional disability given his inability to drive heavy vehicles going forward, using the standard multiplier formula to enhance the loss-of-future-income award by over Rs. 8 lakh. The Court also enhanced compensation for the prosthetic limb (including future maintenance) to Rs. 26,00,000, awarded Rs. 2,00,000 in litigation costs, and directed the insurer to pay a total of Rs. 36,20,350 over and above what the High Court had already awarded, with 9% annual interest if not paid within four weeks. The appeal was allowed.

Lesson Learnt

In motor accident compensation cases involving loss of a limb, courts can look beyond the strict documentary proof of income and recognize the true lifelong cost of a prosthetic device, including its periodic replacement and maintenance, rather than treating it as a one-time expense.

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

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