The Supreme Court has set aside a Karnataka High Court order that reduced compensation granted to a 23-year-old accident victim whose leg had to be amputated after a 2015 road accident. The Bench of Justices K. Vinod Chandran and N.V. Anjaria held that the High Court erred in applying provisions of the Workmen’s Compensation Act, 1923 while dealing with a claim under Section 166 of the Motor Vehicles Act, 1988.
The appellant had sought ₹35 lakh in compensation. The Motor Accident Claims Tribunal (MACT) fixed his monthly income at ₹9,000, assessed disability at 85%, and awarded ₹19.35 lakh under various heads, including pain and suffering, future loss of income, and medical expenses. On appeal by the insurer, the High Court reduced the notional monthly income to ₹8,000 based on the ceiling under the Workmen’s Compensation Act, and cut the compensation to ₹10.41 lakh.
The Supreme Court ruled this approach impermissible, citing its earlier decision in National Insurance Co. Ltd. v. Mastan (2006) 2 SCC 641, which clarified that once a claimant opts for the Motor Vehicles Act route, principles under the Workmen’s Compensation Act cannot be imported. The Court stressed that both remedies are distinct and mutually exclusive under Section 167 of the MV Act.
While restoring the Tribunal’s award of ₹19.35 lakh, the Court declined to entertain the appellant’s plea for addition of “future prospects,” noting that he had not filed a separate appeal against the Tribunal’s decision on that aspect.
Accordingly, the appeal was allowed, the High Court’s order quashed, and the Tribunal’s original award reinstated.
