A) ABSTRACT / HEADNOTE

Parminder Singh v. Honey Goyal & Ors., Civil Appeal No. 4299 of 2025, concerns enhancement of compensation under the Motor Vehicles Act, 1988 for a 21-year-old veterinary student and State-level volleyball player who suffered quadriplegia (100% permanent disability) after being struck by a car on 03.06.2014. The Tribunal originally awarded ₹5,16,000; the High Court enhanced the award to ₹15,25,600 by taking monthly income at ₹5,600 and applying multiplier 18.

The Supreme Court held that:

(i) the income figure was underestimated and should be taken at ₹7,500 per month,

(ii) future prospects of 40% ought to be added, yielding an adjusted monthly income of ₹10,500,

(iii) multiplier 18 was appropriate, and

U(iv) additional heads such as attendant charges, special diet, pain and suffering, physiotherapy and future medical expenses warranted substantial lumpsum awards.

The Court thus enhanced total compensation to ₹36,84,000 and directed payment by bank transfer within specific timelines, while issuing comprehensive directions to streamline direct bank payment of awards in motor accident cases to avoid delay and loss of interest. The judgment takes judicial notice of physiotherapy needs, the minimum wages applicable at the time, and national data on road accidents; it reiterates the Tribunal’s and High Court’s duties to assess realistic future prospects and ancillary heads.

Keywords: quadriplegia, loss of income, future prospects, attendant charges, bank transfer of compensation, Motor Vehicles Act 1988, minimum wage, pain and suffering.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appeal arises from challenge to the High Court’s enhancement of a Tribunal award in a motor accident claim. The claimant was a 21-year-old student and sportsman who, while riding a motorcycle, was hit by a car on 03.06.2014 and thereafter adjudged to have suffered 100% permanent disability (quadriplegia). The Tribunal made a conservative award of ₹5,16,000 which the High Court enhanced to ₹15,25,600 by reassessing loss of income only.

Dissatisfied, the claimant approached the Supreme Court seeking realistic assessment across multiple heads, especially in view of his young age, vocational potential, sporting achievements and technical qualifications. The Supreme Court had to balance absence of positive documentary proof of income against statutory and social reality: contemporaneous minimum wages, earning potential of a young aspirant, and lifelong care costs consequent to quadriplegia.

The Court also confronted systemic procedural friction: delay and interest loss caused by current practice of deposit into Tribunal or treasury rather than direct bank transfer. Drawing on judicial notice (minimum wage schedules and national accident statistics) and precedents concerning direct transfer of compensation in land acquisition contexts, the Court re-evaluated income, applied future prospects, expanded heads of compensation, and laid down nation-wide procedural directions for bank transfer of awards to mitigate delay and financial prejudice to claimants.

The background thus combines individual remedial justice in a catastrophic injury with a policy-oriented procedural reform to ensure timely monetary relief.

D) FACTS OF THE CASE

On 03.06.2014 the appellant riding a motorcycle was struck by a car (Regn. PB-03-X-0169) coming from the opposite direction. The appellant, then aged 21, sustained grievous injuries leading to paralysis of all four limbs (quadriplegia) and was medically certified as 100% disabled by the Orthopaedic Surgeon, Civil Hospital, Bathinda. A criminal case was registered against the car driver.

The appellant was pursuing veterinary studies, had represented in inter-school/international district games (volleyball), and had undertaken a course in pig farming from Punjab Agricultural University credentials signifying vocational skill and youthful potential. He produced receipts showing medical expenditure of ₹2,66,000. The Motor Accident Claims Tribunal awarded a lumpsum ₹2,00,000 for disability and total compensation ₹5,16,000.

The High Court, on appeal, recalculated loss of income by adopting monthly income at ₹5,600 and applying multiplier 18, enhancing the award to ₹15,25,600. The appellant complained that the income figure ignored his technical qualifications, sports background, and present minimum wage benchmarks; he also sought attendant charges, higher special diet and pain & suffering compensation, and recognition of ongoing physiotherapy and future medical needs.

The insurer resisted further enhancement, pointing to absence of documentary proof of current earnings and asserting the High Court’s award was reasonable. In cross-examination issues arose regarding physiotherapy receipts (defective ledger evidence), and the Trial/High Court were conservative on certain ancillary heads. The Supreme Court therefore faced contested evidentiary weight on certain expenditures but clear entitlement to higher compensation for life-long disability and attendant care.

E) LEGAL ISSUES RAISED

1. Whether the income assessed by the High Court at ₹5,600 per month for a 21-year-old with technical qualifications and sporting background was realistic and whether it should be enhanced.

2. Whether future prospects should be awarded in loss of income calculations and, if so, at what percentage.

3. Whether ancillary heads such as attendant charges, special diet, pain and suffering, physiotherapy and future medical expenses must be awarded and in what quantum.

4. Whether direct bank transfer of compensation by insurers to claimants is desirable and what procedural safeguards should be laid down to avoid delay and interest loss.

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for Petitioner submitted that the appellant, a young aspirant with vocational training and State-level sporting credentials, had higher earning potential than the sum assumed by the High Court; that taking income below statutory minimum wage was untenable; that future prospects must be allowed given his age and qualifications; that the catastrophic nature of quadriplegia imposes lifelong attendant and medical costs, special diet and physiotherapy; and that compensation must reflect pain, suffering and loss of marriage prospects. Counsel urged adoption of realistic monthly income, application of multiplier 18, and fresh quantification of non-pecuniary heads.

G) RESPONDENT’S ARGUMENTS

The counsels for Respondent (United India Insurance Co. Ltd.) contended that the High Court’s estimate was reasonable in absence of demonstrative proof of income; that the Tribunal and High Court had appropriately exercised discretion; and that further enhancement was unwarranted. Insurer emphasized evidentiary gaps in receipts for physiotherapy and cautioned against speculative awards. Liability was accepted but quantum, respondent argued, must be conservative.

H) JUDGEMENT 

The Supreme Court allowed the appeal in part and substantially re-quantified compensation. The key findings were:

first, the monthly income figure of ₹5,600 adopted by the High Court was lower than contemporaneous minimum wage (unskilled ₹6,447.75 and semi-skilled ₹7,227.75 w.e.f. 01.03.2014), and taking into account the appellant’s technical course and sporting record the Court fixed ₹7,500 as reasonable monthly income.

Second, the Court applied future prospects at 40% given the appellant’s age and potential, yielding adjusted monthly income ₹10,500 (₹7,500 × 1.4). Third, the multiplier of 18 adopted by the High Court for loss of future earnings was affirmed.

Fourth, the Court awarded substantial lumpsum amounts: attendant charges ₹5,00,000; special diet ₹1,00,000; pain and suffering ₹1,00,000; physiotherapy ₹50,000 (judicial notice taken despite weak receipts); future medical expenses ₹2,00,000; loss of marriage prospects ₹2,00,000.

Combining heads produced total compensation ₹36,84,000 (Loss of income: ₹22,68,000; medical expenses: ₹2,66,000; plus other heads). The Court ordered interest on enhanced sum at same rate as earlier awarded. Importantly, on procedure the Court issued directions to streamline payments: tribunals should collect bank details at pleading stage, require opening of accounts where none exist, ensure accounts are in claimant’s name (or guardian for minors), permit specified fixed-deposit directions to be implemented by banks, and direct insurers to transfer awarded amounts directly into claimant bank accounts within stipulated timelines, with intimation to Tribunal adopting and extending principles applied earlier in land acquisition cases such as Haryana State Industrial Dev. Corp. v. Pran Sukh.

The Court emphasized that direct transfer reduces interest loss, procedural delay and attendant hardships, and is compatible with present digital banking and UPI proliferation. The insurer was directed to transfer the enhanced award within six weeks after claimant provides bank particulars. The Registry was directed to circulate the order to Registrars General and judicial academies for compliance.

a. RATIO DECIDENDI

The controlling ratio is twofold.

First, in assessing loss of income for young claimants, courts must ensure the notional income adopted is not below statutory minimum wages and must account for future prospects when age, qualifications or vocational skills indicate potential for income growth; here minimum wage data and appellant’s credentials justified raising monthly income to ₹7,500 and adding 40% future prospects.

Second, for effective relief in motor accident compensation, courts may and should direct direct bank transfers of award amounts by insurers to claimants to prevent delay and loss of interest; tribunals should collect and verify claimant bank particulars at the earliest stage. These propositions guide both quantification and procedural disbursement of compensation.

b. OBITER DICTA

The Court observed judicially that physiotherapy is ordinarily necessary for severe disabilities and may be recognized even where documentary proof is imperfect; courts can take judicial notice of recurring medical needs in catastrophic injury. The judgment mused on technological progress in banking and digital payments (UPI growth) and urged adaptation of judicial processes to digital disbursement.

It also commented on the national burden of road accidents and backlog of claim petitions as policy context for procedural reform; these observations, while not strictly necessary to decision’s core, signal an administrative and welfare orientation.

c. GUIDELINES 

1. Tribunals should require claimants to furnish and verify bank account particulars at the pleading or evidence stage.

2. If claimant lacks a bank account, tribunal may direct immediate opening of an account (individual or with family member).

3. Bank accounts must be in claimant’s name; minors’ accounts may be held by guardians who must be family members.

4. Insurance companies should transfer awarded amounts directly into claimant accounts and intimate the Tribunal; transfer shall be treated as satisfaction of award.

5. Where tribunal directs a percentage to be kept in fixed deposit, the award should state so and the receiving bank must comply and report to Tribunal.

6. Compliance and intimation protocols should minimize delay and loss of interest; courts/registries and judicial academies to circulate and implement directions.

I) CONCLUSION & COMMENTS

The Supreme Court’s decision advances two complementary strands of remedial jurisprudence: substantive fairness in quantum for catastrophic injuries and procedural efficiency in disbursement. Substantively, the Court insists tribunals and appellate courts avoid unrealistic low notional incomes and must factor future prospects especially for young claimants with vocational promise.

This reflects established compensatory principles compensation must restore, as far as money can, the claimant’s lost earnings and mitigate lifelong care costs and aligns with prior precedents that add prospective increments to base income. Procedurally, the Court’s insistence on direct bank transfer modernises execution of awards, dovetailing with governmental digital payment regimes and existing precedent in land acquisition payments.

Practically, the judgment reduces a significant friction point that caused interest loss and time-cost to vulnerable claimants and streamlines insurer compliance. For lower courts, immediate takeaways include stricter scrutiny of minimum wage data and realistic future prospects quantification; for tribunals, institutionalising bank detail collection and standard terms in awards; for insurers and banks, clear duties to effect fixed-deposit instructions and timely transfer.

The Court’s judicial notice of physiotherapy needs and liberal awarding on certain heads (despite defective receipts) shows a compassionate, purposive approach in welfare litigation courts may weigh evidentiary lacunae against the practical realities of catastrophic injury. Future litigants should therefore ensure early production of bank particulars and documentary proof for medical expenses but may remain reassured that courts will protect claimants from predictable procedural prejudice.

J) REFERENCES

a. Important Cases Referred

1. Haryana State Industrial Development Corporation v. Pran Sukh, (2010) 11 S.C.C. 175.

2. Haryana State Industrial & Infrastructure Development Corporation Ltd. v. Smt. Krishna Rani & Another, R.F.A. No.1492 of 2008 (Order dated 08.04.2011).

3. Parminder Singh v. Honey Goyal & Ors., Civil Appeal No.4299/2025, Judgment dated 18.03.2025 ([2025] 4 S.C.R. 50).

b. Important Statutes Referred

1. Motor Vehicles Act, 1988 (India).

2. Code of Criminal Procedure, 1973 (India).

3. Protection of Women from Domestic Violence Act, 2005 (cited for comparative practice regarding court deposits and maintenance disbursement).