A) ABSTRACT / HEADNOTE

The appeal concerns enhancement of compensation payable to Parminder Singh, a 21-year-old veterinary student and State-level volleyball player, who sustained quadriplegia after being struck by a car on 3 June 2014 and was medically declared 100% disabled. The Motor Accident Claims Tribunal awarded ₹5,16,000; the High Court enhanced the award to ₹15,25,600 by applying a multiplier of 18 but fixing monthly income at ₹5,600 and failing to allow future prospects.

The Supreme Court reviewed the evidence of the claimant’s age, sporting background and technical training, took judicial notice of minimum wages and the lifelong impact of 100% permanent disability, and increased the notional monthly income to ₹7,500 with 40% future prospects (making effective monthly income ₹10,500). The Court additionally awarded lump sums for attendant charges, special diet, pain and suffering, physiotherapy, future medical expenses and loss of marriage prospects, and directed payment by direct bank transfer from the insurer. Total compensation fixed at ₹36,84,000. The judgment also issues practice-directions to streamline disbursal in motor accident matters by requiring bank particulars at the pleadings stage and permitting direct transfer to claimants’ accounts, citing precedents on direct payment in acquisition/compensation matters.

Keywords: Motor Vehicles Act, 1988; Quadriplegia; Loss of income; Future prospects; Attendant charges; Direct bank transfer of compensation; Loss of marriage prospects; Pain and suffering.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appeal arises from a classical MACT claim where the claimant, a young adult pursuing veterinary studies and with sports credentials, suffered catastrophic injuries in a road collision on 3 June 2014, resulting in quadriplegia and a medical finding of 100% permanent disability. The Tribunal’s conservative award (₹5,16,000) prompted a first appeal to the High Court which raised compensation to ₹15,25,600 by applying multiplier methodology but fixed a modest monthly income (₹5,600) and omitted future prospects.

The Supreme Court took the appeal to examine whether the High Court’s methodology and quantification adequately reflected the claimant’s pre-accident potential, the nature of disability, and the lifelong expenditure and attendant care needs such injuries necessitate. The Court’s exercise involves familiar tasks in MACT jurisprudence: selecting an appropriate notional income where actual earnings are absent, applying an appropriate multiplier based on age, assessing future prospects depending on claimant profile, and awarding heads such as attendant charges, special diet, pain and suffering and future medical/therapeutic expenses.

The judgment also addresses systemic payment practices and issues directions for direct bank transfers to avoid delay and loss of interest to claimants, drawing on earlier rulings on direct disbursal in compensation contexts.

D) FACTS OF THE CASE

• On 03.06.2014 the appellant was riding a motorcycle and was struck by a car (Reg. PB-03-X-0169) coming from opposite direction; criminal proceedings were instituted against the car driver.

• The claimant was 21 years old at the time, studying to be a veterinary doctor, had completed a course in pig farming from Punjab Agricultural University and participated in inter-district/international school games (volleyball).

• Injuries led to quadriplegia (paralysis of all four limbs); orthopedic certification recorded 100% disability.

• Medical expenses produced amounted to ₹2,66,000 (receipts). The Tribunal awarded a lump ₹2,00,000 for 100% disability but fixed total compensation at ₹5,16,000.

• On appeal the High Court increased the award to ₹15,25,600, adopting monthly income ₹5,600 and multiplier 18, but declined to allow future prospects.

• The claimant produced physiotherapy receipts from Dr. Satnam Saggu but the receipts could not be corroborated in cross-examination; both Tribunal and High Court declined that head. The Supreme Court accepted judicial notice that physiotherapy will be required and awarded a lump sum.

E) LEGAL ISSUES RAISED

i. Whether the High Court erred in fixing notional monthly income at ₹5,600 without adequately accounting for minimum wage levels and the claimant’s vocational and sporting credentials?
ii. Whether future prospects ought to have been allowed and, if so, at what percentage for a 21-year-old with technical/sports background permanently disabled?
iii. What heads of compensation (attendant charges, special diet, physiotherapy, pain & suffering, future medical expenses, loss of marriage prospects) are appropriate for 100% quadriplegia?
iv. Whether and how the process of payment of MACT awards should be streamlined to avoid delay and loss of interest — can direct bank transfer be ordered as practice-direction?

F) PETITIONER / APPELLANT’S ARGUMENTS

i. The claimant contended that the monthly income fixed by the High Court was unduly low given his age, sports achievements and technical qualifications, and that such under-valuation produced an inadequate loss-of-income award.
ii. He argued for allowance of future prospects (since he was young, educated and skilled) and comprehensive heads to cover attendant care, special diet, physiotherapy and loss of marriage prospects, given the permanence and severity of 100% disability.
iii. Appellant urged the Court to take judicial notice of ongoing physiotherapy needs even where documentary proof was imperfect.

G) RESPONDENT’S ARGUMENTS

i. The insurer resisted further enhancement, submitting that the High Court’s award was reasonable. In absence of reliable proof of income, the notional income of ₹5,600 was said to be acceptable and not amenable to upward revision.
ii. The insurer disputed heads founded on uncorroborated receipts (physiotherapy) and urged the Court to be guided by strict evidentiary standards.

H) RELATED LEGAL PROVISIONS 

i. Motor Vehicles Act, 1988 — statutory regime for MACT claims and compensation principles (notionally invoked throughout award calculation).
ii. Procedural references to Code of Criminal Procedure, 1973 (context of criminal case record) and to Domestic Violence Act, 2005 (illustrative of deposit-and-withdrawal practices).
iii. Precedential practice from Haryana State Industrial Dev. Corpn. v. Pran Sukh (2010) 11 SCC 175 — authority for direct transfer of compensation/award into bank accounts.

I) JUDGEMENT

The Supreme Court allowed the appeal and substantially enhanced compensation to ₹36,84,000. The Court held the High Court’s multiplier usage (18) correct but found the notional income too low: selecting ₹7,500 per month after reference to contemporaneous minimum wages (unskilled ₹6,447.75; semi-skilled ₹7,227.75 w.e.f. 01.03.2014). Applying 40% future prospects (appropriate for a young claimant with technical exposure and sporting background) raised monthly assessable income to ₹10,500 (₹7,500 × 1.4).

Using multiplier 18 for age 21 produced the primary loss-of-income computation: ₹7,500 × 1.4 × 12 × 18 = ₹22,68,000. The Court then assessed and enhanced other heads: medical expenses (actual ₹2,66,000 accepted), attendant charges ₹5,00,000 (lump sum), special diet ₹1,00,000 (enhanced), pain & suffering ₹1,00,000 (enhanced), physiotherapy ₹50,000 (judicially noticed despite weak receipts), future medical expenses ₹2,00,000 and loss of marriage prospects ₹2,00,000 aggregating to ₹36,84,000.

a. RATIO DECIDENDI

The controlling legal ratio is twofold:

(1) where actual income is not proved, Courts must adopt a realistic notional income anchored to contemporaneous benchmarks (minimum wages, claimant’s qualifications/age and vocational prospects) rather than a purely conservative figure;

(2) future prospects are a distinct component of loss of future earnings and must be allowed in a percentage tailored to age, skill and potential thus a 40% uplift was appropriate for a 21-year-old with technical training and sporting achievements permanently disabled. The Court emphasised that 100% permanent disability entails lifelong costs (attendant, special diet, therapy) which must be compensated reasonably. 

b. OBITER DICTA

The Court expressed broad observations on systemic inefficiencies in MACT disbursal practice. It noted contemporary digitisation of payments (growth of UPI and bank penetration) and observed that deposit-then-withdrawal through tribunals causes avoidable delay and loss of interest to claimants. Though procedural and not strictly necessary to decide the compensation quantum, the Court opined that tribunals should require bank particulars at the pleading stage and that insurers may be directed to transfer awards directly into the claimant’s bank account, with courts able to mandate fixed-deposit portions where appropriate. The Court relied on analogous directions in Pran Sukh and subsequent High Court practice to justify such practice-directions. *

c. GUIDELINES 

i. When the claimant’s actual income is not established, courts should fix notional income by reference to minimum wages and the claimant’s qualifications, age and prospects rather than arbitrary low figures. 
ii. Future prospects must be separately quantified; percentages (eg. 30–50%) should be calibrated to claimant’s age, education and skill-profile — in this case 40% for a 21-year-old with technical credentials. 
iii. Courts can and should award lump sums for attendant charges, special diet, pain & suffering, future medical and physiotherapy where disability is permanent and substantial. Judicial notice may be taken of recurring therapeutic needs if documentary proof is imperfect. 
iv. Procedural directions: tribunals should collect claimants’ bank particulars at the outset; insurers should be directed to transfer compensation directly into claimants’ bank accounts; banks should implement any tribunal direction to keep a portion in fixed deposit and report compliance to the tribunal. 
v. Transfer of award into claimant account per particulars stated in the award should constitute satisfaction of the award; courts may prescribe timelines for insurer verification and payment. 

J) CONCLUSION & COMMENTS

The Supreme Court’s approach reaffirms established MACT principles while insisting on realism and claimant-centric calculation: notional income cannot be frozen below minimum wages simply because claimant lacked formal income proofs; future prospects must be quantified where claimant is young and trained. The award recognises the peculiarity of quadriplegia lifelong attendant care and recurring therapy and compensates accordingly. The Court’s procedural directions are practically valuable: by institutionalising early collection of bank details and permitting direct transfer, the judgement addresses avoidable delay and protects claimants’ interest earnings.

For practitioners, the judgment is a useful authority for arguing:

(i) higher notional income based on contemporaneous wage data and claimant’s profile,

(ii) a robust percentage for future prospects for young claimants,

(iii) heads such as attendant charges, physiotherapy and marriage prospects in severe permanent disability cases.

The obiter practice-directions should be invoked in tribunal practice and pleadings to expedite payment and reduce friction between claimants and insurers; courts and tribunals would do well to formalise bank-transfer checklists at filing stage in light of this ruling.

K) REFERENCES

a. Important Cases Referred
i. Haryana State Industrial Development Corporation v. Pran Sukh, (2010) 11 SCC 175.
ii. Haryana State Industrial & Infrastructure Development Corporation Ltd. v. Smt. Krishna Rani & Another, R.F.A. No.1492 of 2008 (High Court practice referred).
iii. Parminder Singh v. Honey Goyal & Others, Civil Appeal No. 4299 of 2025, [2025] 4 S.C.R. 50 : 2025 INSC 361 (subject judgment).

b. Important Statutes Referred
i. Motor Vehicles Act, 1988 (MACT regime).
ii. Code of Criminal Procedure, 1973 (procedural context).
iii. Protection of Women from Domestic Violence Act, 2005 (referenced as context for deposit/withdrawal practice).