COURT’S DECISION
The Court dismissed the insurer’s appeal and upheld the Tribunal’s award of ₹66,33,256 with 7.5% interest, holding that:
- The Tribunal correctly assessed the claimant’s notional income at ₹20,000 per month, considering his professional animation course.
- The 75% permanent functional disability was rightly determined based on medical testimony.
- The disability certificate was duly proved through the doctor’s examination.
- The appeal lacked merit as all three grounds raised were inconsistent with settled law.
The Court reaffirmed that compensation must be just, fair, and based on realistic earning potential, especially in cases involving young students pursuing professional courses.
FACTS
The case arose from a road accident in 2017 in which a 20-year-old professional animation student suffered catastrophic spinal injuries. This resulted in 75% permanent disability in both lower limbs, rendering him wheelchair-bound for life.
The Tribunal found that the accident occurred due to rash and negligent driving. It assessed his notional income as an entry-level animation professional at ₹20,000 per month and granted full compensation under various heads, including future loss of income, medical expenses, lifelong attendant costs, and future prospects.
The insurer challenged this computation, arguing that the claimant was merely a student with no actual income and that minimum wages should have been applied.
ISSUES
- Whether the Tribunal erred in assessing the income of a student pursuing a professional animation course at ₹20,000 per month instead of minimum wages.
- Whether the disability certificate was wrongly relied upon without strict proof.
- Whether the Tribunal erred in treating the claimant’s functional disability as 75%.
- Whether strict evidentiary standards apply to motor accident claims.
- Whether the insurer discharged its burden to disprove the disability assessment.
PETITIONER’S ARGUMENTS (INSURER)
The insurer argued that the Tribunal inflated compensation by considering the claimant’s notional income at ₹20,000 despite his being a student with no earnings. It insisted that minimum wages (₹11,830) should apply. The insurer further argued that the disability certificate was not proved in accordance with strict evidentiary standards and should have been rejected.
It contended that because the claimant could still work with his upper limbs and had completed a computer graphics course, his functional disability should be far lower than 75%. The insurer relied on the principle that functional disability must reflect actual vocational loss and claimed the Tribunal failed to apply this correctly.
RESPONDENT’S ARGUMENTS (CLAIMANT)
The claimant argued that he was pursuing a professional animation course with clear career prospects, and therefore notional income should reflect entry-level salaries in that field, not minimum wages. He highlighted that his testimony on being enrolled in a reputable animation institute was unrebutted.
He emphasised that the disability certificate was issued by a medical board and proved through a doctor who physically examined him, assessed his spinal trauma, and confirmed lifelong wheelchair dependence.
The claimant explained that although he completed a computer graphics course, this did not meaningfully reduce his functional disability, as most animation roles require mobility, long sittings, and workstation ergonomics incompatible with paralysis and wheelchair confinement.
ANALYSIS OF THE LAW
The Court reiterated that motor accident compensation is a beneficial legislation, and that strict rules of evidence applicable to criminal matters do not apply. The correct standard is the preponderance of probabilities, allowing the Tribunal to evaluate documents and expert evidence holistically.
Assessment of Income
The Court relied on settled law that when a student pursues a professional course (e.g., animation, engineering, medical), compensation must consider the future earning capacity, not minimum wages. Professional courses create legitimate expectations of higher income, and this must be factored into just compensation.
Disability Certificate
The Court held that examination of the doctor who issued the certificate fully satisfied the evidentiary burden. The doctor explained the methodology, guidelines, and physical findings, making the certificate credible.
Functional Disability
Functional disability must reflect the impact on vocation; here, paralysis of both lower limbs substantially restricted employability, even though upper limbs functioned normally. The Tribunal assessed it at 75%, balancing the claimant’s educational progress with his permanent physical limitations.
PRECEDENT ANALYSIS
Babli Dixit v. Satendra Kumar — (Delhi High Court)
Principle: Earning capacity of a student pursuing a professional course must be computed considering potential income after course completion.
Applied: Notional income of ₹20,000 for an animation student was upheld.
Rajwati v. United India Insurance Co. — (Supreme Court)
Principle: Motor accident cases follow preponderance of probabilities, not strict evidence rules.
Applied: Disability certificate need not meet strict criminal trial standards.
Sunita v. Rajasthan State Road Transport Corp.
Principle: Claims tribunals must adopt a liberal approach to ensure fair compensation.
Applied: The doctor’s testimony was deemed sufficient proof.
Kusum Lata v. Satbir
Principle: Beneficial nature of Motor Vehicles Act requires flexible evidentiary evaluation.
Applied: Slight procedural irregularities cannot defeat a disability claim.
Raj Kumar v. Ajay Kumar
Principle: Functional disability depends on the nature of work, injuries, and vocational impact.
Applied: Claimant’s animation career significantly impaired → 75% upheld.
All precedents consistently supported rejection of the insurer’s objections.
COURT’S REASONING
The Court meticulously examined evidence and concluded:
- The claimant’s unrebutted testimony established that he was pursuing a professional animation course.
- The Tribunal correctly applied Babli Dixit to compute realistic future income rather than minimum wages.
- The doctor’s cross-examination confirmed that disability assessment followed Government of India guidelines.
- Although the claimant had completed a computer graphics course post-accident, the paralysis of both lower limbs severely restricted employability in animation—justifying 75% functional disability.
- The insurer’s objections were speculative and unsupported by evidence.
The Court held that the Tribunal acted “justly, equitably and consistent with settled legal principles.”
CONCLUSION
The High Court dismissed the insurer’s appeal and upheld:
Compensation of ₹66,33,256
Interest @ 7.5%
75% permanent functional disability
Notional income of ₹20,000
Validity of disability certificate
Refund of statutory deposit
The judgment reinforces that compensation must reflect realistic future suffering, particularly for young students with catastrophic injuries.
IMPLICATIONS
- Reinforces higher notional income for students in professional courses.
- Strengthens the validity of disability certificates supported by medical testimony.
- Establishes that wheelchair confinement significantly impacts future employment despite upper limb functionality.
- Sends a strong message that insurers cannot rely on technical objections to reduce just compensation.
FAQs
1. Can a student get compensation based on future earning capacity?
Yes. Courts compute income based on the profession the student was training for, not minimum wages.
2. Is strict proof required for disability certificates in motor accident cases?
No. The Tribunal relies on preponderance of probabilities; a doctor’s testimony is sufficient.
3. How is functional disability assessed for vocational impact?
Courts consider injuries, job requirements, and long-term physical limitations to determine realistic earning loss.