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Sharad Singh (Dead) Through LR. vs. H.D. Narang

Not available · 2025 INSC 1164Decided 26 Sept 2025
Not available
Justice K. Vinod Chandran · Justice N.V. Anjaria

Background

A 20-year-old man was rendered permanently paraplegic after suffering a C4-5 spinal fracture when a rashly-driven car hit the motorcycle he was riding pillion on, causing him to fall and be run over. The vehicle's owner was driving it himself, and it was insured. The victim (later represented by his mother, and now by his legal representative after his death) appealed only against the quantum of compensation: specifically the income assessed and the future medical expenses claimed through hospital bills from Goa and Bengaluru.

Decision Breakdown

The insurance company disputed some medical bills, arguing they predated the High Court's earlier disposal and were hard to verify given they came from cities away from the victim's home. The Supreme Court held that even though the victim had not completed his Chartered Accountancy qualification, he could reasonably have been employed as an accountant, and fixed his notional monthly income at Rs. 5,000, adding 40% for future prospects as per the Pranay Sethi precedent. This produced a loss-of-income award of Rs. 15,12,000, which combined with Rs. 14 lakh in conventional heads and Rs. 11,22,356 in medical expenses totalled Rs. 40,34,356, carrying 9% interest. The Court additionally awarded Rs. 20 lakh towards future medical expenses for the parents, payable within four months (also carrying 9% interest if delayed).

Lesson Learnt

In motor accident compensation cases, courts will assess a fair and realistic notional income for a young victim even without a completed professional qualification, and will separately account for genuine future medical expenses beyond the standard compensation heads.

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

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