The Supreme Court enhanced compensation for a minor with 77.1% permanent disability by applying established legal parameters from precedents like Pranay Sethi. It recalculated loss of future earnings using a multiplier of 15 and 40% future prospects, and awarded standardized sums under conventional heads including pain and suffering, loss of amenities, and loss of marriage prospects.
Facts Of The Case:
The case pertains to a motor accident on 19.04.2002 involving a 14-year-old minor student travelling in an auto-rickshaw which was hit by a lorry insured with respondent No. 3. The appellant suffered injuries resulting in 77.1% permanent disability. The Motor Accident Claims Tribunal initially awarded Rs. 1,73,000/- with interest. On appeal, the High Court enhanced the compensation by an additional Rs. 5,75,883/-, applying a multiplier of 15 and assessing monthly income at Rs. 3,620/- with 40% future prospects. The appellant, still aggrieved, appealed to the Supreme Court seeking further enhancement. The Supreme Court, guided by its recent precedent in Sona (minor), recalculated the compensation. It upheld the multiplier and income assessment but awarded higher amounts under conventional heads: Rs. 3,00,000/- for pain and suffering, Rs. 3,00,000/- for loss of marriage prospects, Rs. 40,000/- for attendant charges, and consolidated medical expenses at Rs. 50,000/-. Consequently, the total compensation was enhanced to Rs. 15,13,337/-, granting an additional Rs. 7,64,454/- with 8% interest payable by the insurer.
Procedural History:
The procedural history of the case commenced with the filing of a claim petition under Section 166 of the Motor Vehicles Act, 1988 before the Motor Accident Claims Tribunal, Thrissur. The Tribunal awarded a total compensation of Rs. 1,73,000/- with interest. Dissatisfied, the appellant filed MACA No. 89 of 2009 before the High Court of Kerala at Ernakulam, which enhanced the compensation by an additional Rs. 5,75,883/-. Still aggrieved by the quantum, the appellant filed the present Civil Appeal No. 6544 of 2024 before the Supreme Court of India, which further enhanced the total compensation to Rs. 15,13,337/-, thereby modifying the impugned judgment of the High Court.
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Court Observation:
The Supreme Court made key observations in recalibrating the compensation. It affirmed the High Court’s application of a 15 multiplier and the assessment of monthly income at ₹3,620/- with a 40% addition for future prospects, following Pranay Sethi. However, the Court held that conventional heads of compensation must be reasonably assessed in line with contemporary benchmarks and precedents like Kajal and K.S. Muralidhar. It observed that the High Court’s awards under heads such as pain and suffering, loss of marriage prospects, and attendant charges were inadequate for a minor with 77.1% permanent disability. The Court also noted that actual medical expenses should encompass un-billed out-of-pocket costs and future treatment needs. Consequently, it standardized and enhanced these amounts to ensure just and fair compensation.
Final Decision & Judgement:
The Supreme Court allowed the appeal and modified the impugned judgment of the High Court. It awarded a total enhanced compensation of ₹15,13,337/- (rounded off) to the appellant. Consequently, an additional sum of ₹7,64,454/- was directed to be paid by Respondent No. 3 – Insurance Company, along with interest at the rate of 8% per annum from the date of the original application until realization. The insurer was ordered to credit this amount to the appellant’s bank account within eight weeks and file proof of payment before the Tribunal.
Case Details:
Case Title: Riyas vs. P. N. Shinosh & Anr. Civil Appeal No.: Civil Appeal No. 6544 of 2024 Date of Judgement: November 10, 2025 Judges/Justice Name: Justice N.V. Anjaria and Justice K. Vinod Chandran
Download The Judgement Here