In Motor Vehicle Accident Compensation Case The Supreme Court Upholds Assessment of Disability set by Tribunal.

In the case of Rahul v. National Insurance Company Ltd. and another, the Supreme Court overturned a High Court judgment that reduced the awarded compensation to a motor vehicle accident victim. The key issue at hand was the percentage of disability the appellant, Rahul, suffered due to the accident. The Tribunal determined the compensation under the head 'Loss of future income' by taking into account the disability at 25%, awarding compensation accordingly. However, the High Court reduced this disability to 20%, thereby decreasing the total compensation.

The Supreme Court, after reviewing the evidence, particularly the medical records and the testimony of the examining doctor, concluded that the High Court's reduction of disability was unwarranted. The Court highlighted that the appellant, an agriculturist by profession, had sustained significant injuries, including fractures in both hands requiring surgery and the implantation of plates and screws. This significantly impaired his ability to perform his work.

The Supreme Court emphasized the principle that when a Tribunal makes a finding on disability based on evidence, higher courts should not interfere with that finding unless there are compelling reasons to do so. The Court observed: "We are of the view that the reduction of compensation was not required, particularly, when there is no basis in support thereof. Therefore, the judgment passed by the High Court is liable to be interfered with."

The Supreme Court, after considering all these factors, decided to reinstate the Tribunal's assessment of 25% disability. This decision stemmed from the Court's observation that the High Court, in reducing the disability to 20%, had not provided any substantial justification for their deviation from the Tribunal's well-founded assessment and the court held "Without assigning plausible reason, the High Court re-assessed the compensation by reducing the disability suffered by the appellant to 20%. We are of the view that the reduction of compensation was not required, particularly, when there is no basis in support thereof. Therefore, the judgment passed by the High Court is liable to be interfered with."
Essentially, the Supreme Court emphasized that when a lower court, like the Tribunal in this case, arrives at a conclusion based on a thorough examination of the evidence, higher courts should not interfere or modify that decision unless there are very strong and clearly explained reasons to do so, thus the Supreme Court's judgment underscores the importance of providing fair and just compensation to accident victims, considering the long-term impact of their injuries on their lives and livelihoods. It also highlights the importance of proper assessment of disability, relying on medical evidence and expert testimony.

Coram: Justice Sudhanshu Dhulia & Justice R. Mahadevan.
Between: Rahul Vs National Insurance Company Ltd. and another
DOJ: 09/08/2024