The Supreme Court enhanced compensation by revising the income assessment from minimum wages to a prospective income of an accountant, factoring in future prospects as per Pranay Sethi. It also awarded additional future medical expenses, upholding the insurer’s liability for verified costs incurred due to the victim’s paraplegia.
Facts Of The Case:
On 24th October 2001, a 20-year-old man, Sharad Singh, was travelling pillion on a motorcycle when it was hit from behind by a rashly and negligently driven car. The impact caused him to fall onto the road, and he was subsequently run over by the same car. The accident resulted in a C4-5 fracture, rendering him a paraplegic with 100% disability, as certified by AIIMS, and confined him to a bed-ridden state until his death in 2021. The offending vehicle was owned and driven by the first respondent and was duly insured. The victim’s mother, pursuing the claim as his legal representative, sought compensation. The Motor Accidents Claims Tribunal awarded a specific amount, which was later modified by the High Court. The appellant’s challenge before the Supreme Court was restricted to the quantum of compensation, specifically contesting the calculation of loss of income based on minimum wages and the disallowance of certain medical expenses incurred for his long-term care, including treatments in Goa necessitated by Delhi’s adverse climate for his condition.
Procedural History:
The claim was initially adjudicated by the Motor Accidents Claims Tribunal, which awarded compensation. Dissatisfied with the quantum, the appellant approached the High Court, which modified the award, enhancing some components while determining the income based on minimum wages. The legal heirs of the victim then appealed to the Supreme Court, challenging the High Court’s calculation of loss of future earnings and its treatment of certain medical expenses. The Supreme Court, in its appellate jurisdiction, heard the matter and delivered the present judgment, allowing the appeal in part by further enhancing the compensation under both contested heads.
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Court Observation:
The Supreme Court made key observations on two primary issues. Regarding income assessment, it rejected the application of minimum wages for a skilled worker, reasoning that a final-year B.Com student enrolled for Chartered Accountancy exams possessed superior academic prospects. The Court held that even without the CA qualification, his potential earnings as an accountant justified a higher notional income, to which future prospects were rightfully added. On the medical expenses, the Court dismissed the insurer’s objection to bills from outside Delhi, accepting the explanation that the victim’s paraplegic condition and pneumonia necessitated a move to a more suitable climate. It consequently allowed verified future medical expenses incurred by the parents to sustain the victim for two decades.
Final Decision & Judgement:
The Supreme Court allowed the appeal and enhanced the total compensation. It revised the calculation for loss of future income by adopting a notional monthly income of Rs. 5,000/- with a 40% addition for future prospects, applying a multiplier of 18, resulting in Rs. 15,12,000/- under this head. This amount was added to the conventional heads of Rs. 14 lakhs and medical expenses of Rs. 11,22,356/-, totalling Rs. 40,34,356/-, which carries 9% interest from the petition’s filing date. Additionally, the Court directed the Insurance Company to pay a further Rs. 20 lakhs towards the verified future medical expenses incurred by the parents, which will not carry interest if paid within four months, failing which it will attract 9% interest from the judgment date.
Case Details:
Case Title: Sharad Singh (Dead) Through L.R. vs. H. D. Narang & Anr. Criminal/Civil Appeal No.: Civil Appeal No. 8136 of 2024 Date of Judgement: September 26, 2025 Judges/Justice Name: Justice K. Vinod Chandran and Justice N.V. Anjaria
Download The Judgement Here