Supreme Court Sets Aside High Court’s Direction Requiring Insurer to Provide Prosthetic Limbs, Wheelchair, Travel Costs and Ongoing Assistance to Accident Victim: “Future Wellbeing Can Only Be Compensated in Monetary Terms” — Enhances Award by ₹12 Lakhs

Court’s Decision

The Supreme Court allowed the appeal filed by the insurance company, setting aside the High Court’s direction requiring it to provide prosthetic limbs, a motorized wheelchair, travel costs, and ongoing assistance to the accident victim. The Court held:

“The Insurance Company which has indemnified the owner of the motor vehicle… cannot be required to ensure the future wellbeing, which in any event can be computed in monetary terms and awarded as ‘just compensation’.”

Instead, the Court enhanced the monetary compensation by ₹12,00,000 to cover the cost of prosthetics and mobility aids, directing that this be paid with 6% simple interest within two months.

Facts

The case arose from a motor accident that occurred on 21 December 2008. The claimant, working as a cleaner, was travelling in a Tempo owned by his employer, which collided with a stationary tanker due to rash and negligent driving. As a result of the accident, the claimant suffered severe injuries, leading to 90% impairment in both lower limbs, one of which was amputated.

Medical evidence from doctors and a medical technician confirmed the extent of the disability, and a disability certificate (PW-3/A) was issued. The Motor Accident Claims Tribunal assessed the monthly income at ₹4,000, added 50% for future prospects, applied a multiplier of 17, and adopted 100% functional disability, awarding ₹16,34,400 with 9% interest.

The insurance company did not appeal the award. The claimant, however, filed an appeal before the High Court seeking enhanced compensation.

Issues

1. Whether an insurer can be directed to provide prosthetic limbs and a motorized wheelchair to the accident victim.
2. Whether the future wellbeing of the accident victim, including recurring needs like replacement of assistive aids, can be a continuing obligation on the insurer.
3. What would constitute just compensation in the facts of the case.

Petitioner’s (Insurer’s) Arguments

The insurance company contended:

• Its liability is limited to indemnifying the insured for the loss of estate in pecuniary terms.
• The High Court’s direction requiring it to provide physical aids, cover travel costs, and monitor the future wellbeing of the victim went beyond the statutory obligation of an insurer.
• Such obligations should be quantified in monetary terms and incorporated in the compensation award, rather than imposed as continuing duties.

Respondent’s Arguments

The accident victim, who had filed the appeal before the High Court, sought compensation adequate to meet his long-term mobility needs and wellbeing, which led the High Court to pass a detailed direction for providing physical aids and support.

Analysis of the Law

The Supreme Court reaffirmed the legal position that compensation under the Motor Vehicles Act is to be paid in monetary terms as “just compensation.” It held that while the High Court’s direction was idealistic and intended for the wellbeing of the victim, it was legally unsustainable.

The Court clarified that:

“Future wellbeing… can be computed in monetary terms and awarded as ‘just compensation’.”

Therefore, the obligation of the insurer ends with the payment of such quantified compensation.

Precedent Analysis

Although no specific precedents were cited in the judgment, the Court’s reasoning aligns with the consistent jurisprudence that compensation for personal injury or disability must be awarded in monetary terms and not in the form of continuing obligations on the insurer.

Court’s Reasoning

• The Court noted that the victim, 22 years old at the time of the accident, would require long-term mobility aids.
• On a conservative estimate, the cost of one prosthetic limb was placed at ₹2 lakhs with a life span of 5 years. The Court estimated the need for at least five replacements over a lifetime, amounting to ₹10 lakhs.
• A motorized wheelchair was estimated to cost ₹40,000 and would similarly require replacements, leading to an additional ₹2 lakhs over time.

Accordingly, the Court directed an additional ₹12 lakhs as monetary compensation in lieu of the High Court’s directives:

“We are not increasing the award but only stating the award in monetary terms as is prayed now before this Court by the Insurance Company.”

Conclusion

The Supreme Court allowed the insurer’s appeal, set aside the High Court’s directions for physical aid, and instead awarded an additional ₹12 lakhs with 6% simple interest to the victim, to be paid within two months. The Court directed the claimant to provide bank account details to facilitate online transfer of the balance amount, after deducting any previously paid sums.

Implications

This judgment reinforces that insurers’ obligations are confined to financial compensation and cannot extend to ongoing responsibilities like monitoring or ensuring physical wellbeing. The Court balanced the equities by enhancing compensation, thereby protecting the interests of both insurer and victim without burdening the insurer beyond statutory limits.

It sets a precedent against expanding insurer liability into non-monetary or service-based obligations and emphasizes quantification of all heads of damages in pecuniary terms under the Motor Vehicles Act.

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