Reliance General Insurance Company Limited v. Priyanka Das
Background
On 10 April 2011, Sushant Prabhakaran was riding a motorcycle with Priyanka Das as pillion rider when a speeding truck hit them; Prabhakaran fell under the truck's wheels and died instantly, while Das suffered grievous injuries including total blindness and a permanent colostomy. Two separate compensation claims arose from the same accident: one by the deceased's parents and Das over his death, and one by Das over her own injuries. The Motor Accident Claims Tribunal and the Punjab and Haryana High Court awarded compensation in both claims, but the insurer (Reliance General) and the claimants cross-appealed to the Supreme Court over the quantum, the multiplier used, and whether Das qualified as the deceased's legally wedded wife for apportionment purposes.
Decision Breakdown
On the death claim, the Court upheld the multiplier of 16 based on the deceased's age (33), following settled precedent that the multiplier tracks the deceased's age, not the dependents'. It declined to disturb the finding that Das was not proven to be the legally wedded wife (no documentary proof of marriage), and dismissed the insurer's appeals while leaving the High Court's compensation figure intact. On the injury claim, the Court ordered a fresh medical evaluation by a Government hospital board, which found Das had suffered 100% permanent physical impairment (total blindness plus permanent stoma). Applying this finding, the Court raised her functional disability assessment from the High Court's 80% to 100%, recalculated future income loss using a 16 multiplier and 50% future prospects addition, and enhanced her total compensation to approximately Rs. 3.77 crore with 7.5% interest, allowing her appeal in part while dismissing the insurer's appeal.
Lesson Learnt
In motor accident claims, courts apply the multiplier based on the deceased's or victim's age under a fixed, standardised table, and functional disability for compensation purposes is measured by real-world loss of earning capacity in the open market, not merely by the fact that an employer has accommodated the victim in their existing job.