Should a medical board’s disability certificate and pre-accident income tax returns prevail over a tribunal’s functional assessment and conjectural income estimates in motor-accident compensation enhancement?

LawSikho
September 8, 2025
Category: Supreme Court of India

Summary

Category	Data
Court	Supreme Court of India
Case Number	C.A. No.-012098-012099 – 2024
Diary Number	27177/2022
Judge Name	HON’BLE MR. JUSTICE K. VINOD CHANDRAN
Bench	HON’BLE MR. JUSTICE K. VINOD CHANDRAN; HON’BLE MR. JUSTICE N.V. ANJARIA
Precedent Value	Binding
Overrules / Affirms	Affirms High Court’s 50% functional disability and acceptance of income-tax returns Overrules limitation on medical, attendant, prosthetic-limb expenses and denial of future-servicing costs Disallows future-prospect enhancement
Type of Law	Motor-Accident Compensation
Questions of Law	Whether a medical board’s disability certificate must be accepted Whether pre-accident income-tax returns can be disregarded on surmise Whether future prospects and capped medical expenses are permissible in disability-based awards
Ratio Decidendi	The Court held that: (1) medical-board certificates of hemipelvectomy disability are admissible without oral evidence, but compensation is determined by functional (earning-capacity) disability—in this case 50% (2) genuine pre-accident income-tax returns cannot be discarded on conjecture—the petitioner’s income is fixed at ₹1,91,000 p.a., multiplier 18, 50% disability (3) future prospects enhancement is inappropriate where disability allows business continuance (4) all proved medical expenses, attendant charges and prosthetic-limb costs (past and reasonable future servicing) must be fully reimbursed
Logic / Jurisprudence / Authorities Relied Upon by the Court	Functional disability (loss of earning capacity) governs compensation, not pure medical percentage Income-tax and sales-tax returns are reliable evidence of pre-accident income Future prospects are not added where disability does not preclude business activities Full invoiced medical expenses, attendant fees, prosthetic-limb purchase and reasonable future servicing are recoverable
Facts as Summarised by the Court	On 09.04.2007 the claimant’s motorbike was hit by a rashly driven truck. The claimant suffered hemipelvectomy (amputation of one leg plus part of pelvic bone). The tribunal assessed 45% disability and monthly income at ₹4,500; awarded ₹13.23 lakhs. High Court enhanced disability to 50%, monthly income to ₹8,000, medical expenses to ₹8 lakhs, plus ₹3 lakhs for pain and amenities (total ₹23.09 lakhs).
Citations	2025 INSC 1076; Civil Appeal Nos. 12098–12099 of 2024 (paras 7–12)

Practical Impact

Category	Impact
Binding On	All subordinate courts adjudicating motor-accident claims
Persuasive For	High Courts considering disability assessment and income proofs
Overrules	High Court’s limitations on medical expense awards and exclusion of attendant/prosthetic expenses Denial of future servicing costs and prospect enhancement
Follows	Established principle that compensation rests on functional disability, not just medical percentage; acceptance of genuine tax returns as income evidence

What’s New / What Lawyers Should Note

The Supreme Court accepts a medical board’s hemipelvectomy disability certificate without requiring oral evidence, yet bases compensation on functional (earning-capacity) disability.
Genuine pre-accident income-tax returns cannot be discarded on mere surmise; income fixed at ₹1,91,000 p.a. with multiplier 18 and 50% disability.
Future-prospect enhancement is impermissible where the claimant can continue his business post-disability.
Full invoiced medical expenses (₹12,54,985), attendant charges (₹1 lakh), prosthetic-limb purchase (₹4,70,805) and a reasonable estimate (₹10 lakhs) for future servicing/accessories must be awarded.

Summary of Legal Reasoning

Admissibility of medical certificate: A medical board’s hemipelvectomy certificate is admissible without viva voce evidence; however, compensation hinges on functional disability relative to earning capacity (para 7).
Assessment of disability: Given the claimant’s business continuity and prosthetic leg, 50% functional disability is reasonable (para 7).
Income proof: Income-tax returns for AY 2007-08 (FY 2006-07) showing gross ₹1,96,000 (net ₹1,91,000) are reliable; tribunal’s rejection on conjecture was unjustified (para 8). Multiplier 18 with 50% disability yields ₹17,19,000 (para 12).
Future prospects: Enhancement for future prospects (40%) is unsustainable where disability does not preclude business; thus, disallowed (para 9).
Medical and related expenses: Entire invoiced medical expenses (₹12,54,985), plus past attendant expenses and prosthetic-leg costs awarded originally by tribunal, are payable; an additional ₹10 lakhs is reasonable for future servicing (paras 10–11, 12).

Arguments by the Parties

Petitioner (Claimant)

Medical board certificate shows 90% amputation disability.
Income-tax returns must be accepted; tribunal’s finding was conjectural.
Future medical and prosthetic servicing costs are unprovided and necessary.

Insurance Company

Income-tax returns were cooked given undergraduate status at accident time.
Future prospects are not granted in disability-based compensation.
High Court’s award is adequate; no further enhancement warranted.

Factual Background

The claimant on 09.04.2007, while riding a motorbike with a pillion, was struck by a rashly driven truck. Negligence of the truck driver was established; both vehicles were duly licensed and insured. Following hemipelvectomy amputation, the Motor Accident Claims Tribunal assessed 45% disability, ₹4,500 monthly income, and awarded ~₹13.23 lakhs. The High Court enhanced disability to 50%, income to ₹8,000, medical expenses to ₹8 lakhs, and added ₹3 lakhs for pain and amenities, totaling ~₹23.09 lakhs.

Statutory Analysis

Employees’ Compensation Act, 1923 schedule used by tribunal to correlate medical amputation percentages (90% for bilateral amputation) but misapplied to single-leg amputation.
Motor Accident Compensation jurisprudence affirms focusing on functional earning capacity over raw medical percentages.
No other statutory provisions were interpreted or “read down” in this judgment.

Alert Indicators

✔ Precedent Followed – functional-disability approach and acceptance of tax returns.
🚨 Breaking Precedent – full reimbursement of all invoiced medical and prosthetic expenses, including future servicing.

Citations

2025 INSC 1076 (para 7–12)
Civil Appeal Nos. 12098–12099 of 2024, Supreme Court of India, Judgment dated 04.09.2025.