A) ABSTRACT / HEADNOTE

Parminder Singh v. Honey Goyal & Ors., Civil Appeal No. 4299 of 2025 (Supreme Court, 18 Mar. 2025) concerns enhancement of compensation in a Motor Vehicles Act, 1988 claim where the 21-year-old claimant suffered quadriplegia and was declared 100% disabled after being struck by a car. The Tribunal awarded a conservative lump sum; the High Court increased it by reassessing monthly income and applying multiplier methodology but omitted future prospects.

The Supreme Court further revised the assessment: it found the monthly income assessment low compared to contemporaneous minimum wages, fixed a realistic monthly income, applied a 40% future prospects uplift, adopted multiplier 18, and granted lumpsum awards for attendant charges, special diet, pain and suffering, physiotherapy, future medical expenses and loss of marriage prospects arriving at ₹36,84,000 with interest.

The Court also addressed systemic delay and operational friction in disbursing awards and directed streamlined direct bank transfers of compensation with procedural safeguards (bank particulars at pleadings stage; fixed deposit directions where appropriate). The judgment reiterates the compensatory object of the Motor Vehicles Act and endorses technology-enabled payments to prevent loss of interest and hardship to claimants.

Keywords: Motor accident compensation; quadriplegia; loss of income; future prospects; attendant charges; direct bank transfer; physiotherapy; pain and suffering; multiplier; Motor Vehicles Act, 1988.

B) CASE DETAILS 

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appeal stems from a motor accident on 03.06.2014, wherein the appellant, then 21 years, riding a motorcycle, was hit by a car and suffered quadriplegia, declared 100% disabled. The Tribunal awarded ₹5,16,000; the High Court enhanced compensation to ₹15,25,600 by reassessing monthly earnings at ₹5,600 and applying multiplier 18. The claimant contested before the Supreme Court seeking further enhancement on grounds that the income estimate undervalued his earning capacity, failed to account for future prospects, and inadequately compensated attendant needs, diet, physiotherapy and pain and suffering.

The State of Punjab & Haryana High Court had earlier adopted minimum wage comparisons in other contexts to ensure fairness; the Supreme Court examined national wage data, the claimant’s qualifications (sports participation and vocational training), and statutory/precedential practice for payment of compensation. The Court balanced admissible evidentiary gaps (e.g., physiotherapy receipts unsupported by counterfoils) against judicial notice of care needs following 100% disability, and fashioned an award that both corrected income assessment and provided for attendant / medical lifecycle needs while addressing procedural inefficiencies in award disbursal.

D) FACTS OF THE CASE

The appellant was driving a motorcycle when a car (Regn. No. PB-03-X-0169) struck him from the opposite direction on 03.06.2014. He incurred grievous injuries which resulted in paralysis of all four limbs (quadriplegia) and was medically certified as 100% disabled. At the time he was a veterinary student, a State Level volleyball player, and had vocational exposure including a pig-farming course from Punjab Agricultural University. He incurred ₹2,66,000 in medical expenses and initially received a lump sum of ₹2,00,000 for disability from the Tribunal.

The Tribunal’s total award of ₹5,16,000 was criticized by the appellant as inadequately reflecting loss of future earnings, attendant needs, physiotherapy, diet, pain and suffering and socio-economic consequences such as loss of marriage prospects. The High Court increased the award, fixing income at ₹5,600 per month and awarding ₹12,09,600 under loss of income but did not apply a future prospects multiplier.

The insurance company accepted liability under a valid policy but contested further enhancement. Evidence on physiotherapy expenses existed in receipts but was imperfectly supported in cross-examination.

E) LEGAL ISSUES RAISED

i. Whether the income of the appellant was correctly assessed at ₹5,600 per month for computation of loss of income?
ii. Whether future prospects ought to be applied to the appellant’s assessed income and at what percentage?
iii. Whether additional heads such as attendant charges, special diet, physiotherapy, future medical expenses, pain & suffering and loss of marriage prospects should be awarded and in what quantum?
iv. Whether the mode of payment of compensation in motor accident awards should be reformed to permit direct bank transfer to claimants to avoid delay and loss of interest?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for Petitioner / Appellant submitted that the claimant was a young, employable person with vocational and sporting credentials and thus the High Court’s adoption of ₹5,600 per month was unrealistically low. The counsels for Petitioner / Appellant submitted that the claimant would have enjoyed future prospects which must be recognized; the permanent 100% disability calls for substantial lifelong attendant and medical support, physiotherapy and special diet; the award must compensate non-pecuniary losses including pain, suffering and loss of marriage prospects; and inadequately supported receipts for physiotherapy should not preclude a judicially prudent allowance given the nature of the injuries.

G) RESPONDENT’S ARGUMENTS

The counsels for Respondent submitted that the High Court had already enhanced the Tribunal’s award reasonably, and in absence of concrete proof of a higher pre-accident income there was no ground to further uplift the monthly income. The counsels for Respondent contended that undocumented or weakly supported claims (physiotherapy receipts lacking counterfoils) cannot be the basis for additional awards and that the insurer’s liability had been accepted and satisfied by the High Court’s order.

H) RELATED LEGAL PROVISIONS 

i. Motor Vehicles Act, 1988 — statutory framework for claims and compensation.
ii. Principles of pecuniary compensation in motor accident jurisprudence: assessment of loss of income, multipliers and future prospects.
iii. Precedent authority on direct payment of compensation—Haryana State Indus. Dev. Corpn. v. Pran Sukh (2010) 11 SCC 175 and Haryana State Indus. & Infra. Dev. Corpn. Ltd. v. Krishna Rani (R.F.A. No.1492 of 2008) – for bank transfer practice.

I) JUDGEMENT

The Supreme Court allowed the appeal and further enhanced compensation to ₹36,84,000. The Court found the High Court’s income estimate unrealistically low in light of contemporaneous minimum wages (₹6,447.75 for unskilled; ₹7,227.75 for semi-skilled as of 01.03.2014) and the claimant’s educational and sporting credentials. The Court fixed the appellant’s monthly income at ₹7,500 and applied future prospects of 40%, arriving at a notional monthly earning of ₹10,500 (₹7,500 × 1.4).

Applying multiplier 18 and 12 months, loss of income computed to ₹22,68,000. The Court awarded attendant charges ₹5,00,000 (lump sum), enhanced special diet from ₹25,000 to ₹1,00,000, awarded pain & suffering ₹1,00,000, physiotherapy ₹50,000 (despite defective receipts, taking judicial notice of need), future medical expenses ₹2,00,000 and loss of marriage prospects ₹2,00,000. Pre-existing Tribunal award for medical expenses ₹2,66,000 was maintained.

The Court directed payment with interest, and imposed timelines on the insurer to effect direct transfer into the claimant’s bank account after verification of particulars furnished within two weeks. The Court issued procedural directions to Tribunals to obtain bank particulars at early stages to facilitate direct transfer, and permitted fixation of portions in fixed deposits by bank compliance if so ordered.

a. RATIO DECIDENDI

The ratio lies in:

(1) treating realistic minimum wage comparisons and the claimant’s background to fix credible notional income where direct proof is absent;

(2) accepting 40% future prospects for a young claimant deprived of working life by 100% disability;

(3) applying an appropriate multiplier (18) commensurate with age; and

(4) recognizing attendant, diet, physiotherapy and non-pecuniary losses as integral to just compensation in catastrophic disability.

The Court reasoned that the compensatory object of the Act requires a forward-looking, humane assessment rather than a conservative arithmetic constrained by lack of documentary proof when claimant characteristics and contemporaneous benchmarks justify uplift.

b. OBITER DICTA

The Court spoke at length about systemic inefficiencies in award disbursal. Observations included that deposit-before-Tribunal practice causes delay, loss of interest and administrative friction; technology and UPI penetration make direct bank transfers feasible; Tribunals may demand bank particulars at pleadings stage; banks must comply with fixed deposit directions; and courts may apply this mechanism in all matters involving monetary awards. These observations are persuasive guidance and not strictly necessary to the adjudication of quantum but serve as strong directions to streamline compensation disbursal.

c. GUIDELINES 

1. Tribunals should require claimants to furnish bank particulars early in proceedings with proof of account and identity.

2. If no account exists, claimants must be asked to open accounts individually or jointly (with family members) before final award.

3. Bank accounts must be in claimant’s name; minors via guardian only. No joint accounts with non-family persons.

4. Insurance companies may directly transfer compensation to claimant accounts as directed in awards; such transfer shall constitute satisfaction.

5. Where awards direct parking a portion in fixed deposit, banks must ensure compliance and report to Tribunal.

6. Change in bank particulars during pendency must be notified to Tribunal.

7. Registrars General and judicial academies to circulate and implement these directions for uniform compliance.

J) CONCLUSION & COMMENTS

The judgment demonstrates principled correction of under-estimation in compensation by anchoring notional income to minimum wage benchmarks and claimant’s vocational profile. By awarding a significant lumpsum for attendant care, diet, physiotherapy and future medical needs the Court acknowledged the multi-dimensional economic and non-economic consequences of 100% disability. Judicial notice used prudently to allow physiotherapy despite imperfect receipts balances evidentiary rigor with remedial compassion.

Procedural directions for direct bank transfer are forward-looking and likely to reduce delay, exposure to intermediaries, and loss of interest promoting the compensatory aim of the Act. The judgment reinforces that where documentary proof of pre-accident income is sparse for young claimants, courts may rely on contemporary wage indicators and claimant credentials to arrive at a fair estimate. The Court’s approach aligns with prior supervisory decisions on direct payment in acquisition and compensation contexts, thereby harmonizing practice across compensation jurisprudence.

K) REFERENCES

a. Important Cases Referred

1. Parminder Singh v. Honey Goyal & Ors., Civil Appeal No. 4299 of 2025, [2025] 4 S.C.R. 50 ; 2025 INSC 361.

2. Haryana State Industrial Development Corporation v. Pran Sukh & Ors., (2010) 11 SCC 175.

3. Haryana State Industrial & Infrastructure Development Corporation Ltd. v. Smt. Krishna Rani & Anr., R.F.A. No.1492 of 2008 (High Court of Punjab & Haryana decisions referenced in judgment).

b. Important Statutes Referred

1. Motor Vehicles Act, 1988.

2. Code of Criminal Procedure, 1973.

3. Protection of Women from Domestic Violence Act, 2005.