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Sanjay Rajpoot v. Ram Singh & Ors.

Civil Appeal · 2025 INSC 188Decided 11 Feb 2025
Civil Appeal No. 2321 of 2025 (arising out of SLP(C) No. 16541/2024)
Justice Sanjay Karol · Justice Prashant Kumar Mishra

Background

The 23-year-old appellant was riding his motorcycle when a vehicle coming from the wrong side struck him, resulting in the amputation of his right leg above the knee. The Motor Accident Claims Tribunal awarded him Rs. 6,70,000 based on a notional income and 50% disability; the High Court enhanced this only modestly. He appealed to the Supreme Court arguing his income, age, and functional disability had all been under-assessed.

Decision Breakdown

The Court corrected his age to 22 years (not 26) based on his Matriculation Certificate, Aadhar, and PAN card, applying a multiplier of 18 per Sarla Verma v. DTC. It held that since he was self-employed and needed to move around for his work, his amputation caused a functional disability far beyond the medically-assessed 50%. The Court fixed it at 90%. Applying current heads of compensation (future prospects, medical expenses, attendant charges, loss of marriage prospects, pain and suffering, assistive device costs), it raised the total award to Rs. 28,93,494.

Lesson Learnt

In motor accident compensation cases, courts must assess "functional" disability, how an injury actually affects a person's ability to earn a living, rather than relying only on a medical disability percentage, particularly for self-employed claimants; documentary records like birth certificates should govern age determination.

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

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