The Supreme Court enhanced the compensation awarded to a road accident victim, recognizing errors in the lower courts' assessment of the victim’s disability and income. The claimant’s compensation was increased from Rs. 1.27 lakhs to Rs. 2.42 lakhs, with the Court highlighting the importance of accurate evaluation of disability and proper consideration of the claimant's income, especially in cases involving long-term impairment.

1. Case Overview

The appellant challenged the Madhya Pradesh High Court's order dated 21.01.2019, which had increased the compensation awarded by the Motor Accidents Claims Tribunal (MACT) from Rs. 87,700 to Rs. 1,27,700, arguing that the compensation was still insufficient.

2. Facts Not in Dispute

The occurrence of the accident on 23.04.2013, the injuries sustained by the appellant, the consequential disability, and the insurance policy's validity were undisputed facts. The core issue before the Court was whether the compensation should be further enhanced.

3. Medical Evidence and Disability Assessment

The Tribunal had originally assessed the appellant's whole body disability at 10%, despite medical evidence presented by Dr. Alok Mehta (PW-5) stating it was 17%. The Supreme Court criticized the Tribunal and High Court for reducing the disability percentage without any contrary evidence, citing previous judgments emphasizing the importance of adhering to medical expert opinions.

4. Precedent and Legal Principles

The Supreme Court referred to past judgments, including Raj Kumar v. Ajay Kumar and Laxman Alias Laxman Mourya v. Oriental Insurance Co. Ltd., which underscore the need to award adequate compensation for physical injuries, pain, suffering, and loss of amenities due to disability.

5. Income Reassessment

The Supreme Court found the lower courts' assessment of the appellant's income at Rs. 3,500 per month to be on the lower side. Given the appellant’s 30 years of experience as a mechanic, the Court revised the monthly income to Rs. 6,500, leading to a recalculation of the compensation for loss of future income.

6. Enhanced Compensation

The Supreme Court enhanced the total compensation under various heads, including future income loss, medical expenses, and pain and suffering, bringing the total to Rs. 2,42,120. The Court directed the insurance company to pay the balance amount with 7% interest within six weeks.

7. Conclusion

The appeal was allowed, with the Supreme Court correcting the lower courts' errors and ensuring the appellant received just compensation in light of the injuries sustained and the impact on his future earning capacity.