R. Logeshkumar vs. P. Balasubramaniam & Anr.
Background
On 26 January 2012, the appellant, then a 21-year-old accounts assistant earning about Rs. 9,000 a month, was riding his two-wheeler in Chennai when a jeep coming from the opposite direction, driven rashly and without sounding a horn, hit him and caused grievous injuries including hemiparesis, disfigurement and brain damage. The Motor Accidents Claims Tribunal awarded him Rs. 3,98,017, which the Madras High Court enhanced to Rs. 14,65,617 after finding 100% functional disability. He appealed to the Supreme Court seeking further enhancement.
Decision Breakdown
The Supreme Court held that Tribunals and courts are not restricted to the amount originally claimed and must award "just compensation" based on the evidence on record. It added one-third of the assessed monthly income as future prospects, raising the loss-of-earnings component substantially, and granted a lump sum of Rs. 3,00,000 for a personal attendant given the appellant's young age and permanent disability. However, it declined to award additional reimbursement for medical expenses that were never proved before the Tribunal and were introduced only as late additional evidence before the High Court. The total compensation was raised to Rs. 21,75,681, with 7.5% interest from the date of filing the claim, and the appeal was allowed in part.
Lesson Learnt
Compensation in motor accident cases is not capped by what a claimant originally asked for, courts can award more if justified by evidence, but claimants should place all supporting evidence (such as medical bills) before the Tribunal at the first opportunity, since evidence introduced late is far less likely to be accepted.