The Supreme Court on Wednesday enhanced the motor accident compensation awarded to R. Halle from ₹35.61 lakh (as reduced by the Madras High Court) to ₹97.73 lakh, restoring and expanding the award granted by the Motor Accidents Claims Tribunal, Coimbatore.
A bench comprising Justices Prashant Kumar Mishra and Sandeep Mehta allowed the appeal arising out of SLP (C) Diary No. 37186 of 2023 and set aside the judgment dated 11.01.2022 passed by the High Court in C.M.A. No. 3595 of 2021. The Court directed the Reliance General Insurance Company Limited to deposit the enhanced amount along with interest @ 7.5% p.a. from the date of petition till realisation, with liberty to recover the same from the driver-cum-owner of the offending vehicle.
The accident occurred on 05.05.2016 at Periyanaickenpalayam, Coimbatore, when the appellant-claimant, then aged about 30 years and working as a Manager at Flyjac Logistics Pvt. Ltd. earning ₹25,000/- per month, was proceeding on his motorcycle (TN-38-BY-9380). The offending motorcycle (TN-38-CD-5823) driven by R. Chinnadurai in a rash and negligent manner collided head-on with him. The appellant sustained grievous injuries including head trauma, facial injury and left femur fracture, leading to 63% permanent disability as certified by the Medical Board. The neuropsychological report further revealed severe impairment in verbal and visual memory, frontal lobe dysfunction and an IQ of 65 (Mild Intellectual Disability).
The MACT, after appreciating the disability certificate, neuropsychological assessment and salary records, awarded ₹65,53,811/- under various heads, including ₹51,40,800/- towards loss of future earning capacity (applying 63% disability and multiplier of 17). The insurer was directed to satisfy the award with liberty to recover from the driver.
The High Court, while dismissing the claimant’s appeal for enhancement and partly allowing the insurer’s appeal, reduced functional disability to 30% and slashed compensation to ₹35,61,000/-, curtailing amounts under loss of amenities and pain & suffering without detailed reappreciation of medical evidence.
Justice Sandeep Mehta, authoring the judgment, reiterated the principles laid down in Raj Kumar v. Ajay Kumar (2011) 1 SCC 343 and held that physical disability cannot be mechanically equated with loss of earning capacity. However, any departure from the Medical Board’s assessment requires cogent reasons supported by *contra* evidence. The Court observed that the High Court had failed to undertake such analysis and had abruptly reduced functional disability without justification.
Emphasising the welfare object of the Motor Vehicles Act, 1988, the bench held:
“…when an appellate court interferes with findings of fact duly recorded by the Motor Accidents Claims Tribunal, particularly on issues such as assessment of disability and loss of earning capacity, it is incumbent upon it to undertake a thorough reappreciation of the evidence and to assign cogent, clear and convincing reasons for departing from the conclusions arrived at by the Motor Accidents Claims Tribunal.”
The Court found that the cumulative effect of the head injury, cognitive impairment, partial blindness and orthopedic limitations rendered the appellant totally incapable of discharging managerial responsibilities, warranting assessment of functional disability at 100%. Accordingly, loss of future earning capacity was recalculated at ₹81,60,000/- (₹40,000 × 12 × 100% × 17), with other heads restored/enhanced, leading to the total compensation of ₹97,73,011/-.
The appeal was allowed. The impugned judgment of the High Court and the MACT award stand modified accordingly. Pending applications, if any, stand disposed of.
Case Title: R. Halle v. Reliance General Insurance Company Limited| 2026 INSC 260
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