Supreme Court Enhances Compensation in Motor Accident Claim: Jitendra vs. Sadiya & Ors. (2025)

Date of the Judgment: February 7, 2025

Citation: 2025 INSC 166

Judges: Hon’ble Justices Sanjay Karol and Prashant Kumar Mishra

When a young labourer’s hand was tragically amputated in a thresher machine accident, the quest for fair compensation led to a protracted legal battle. The Supreme Court of India stepped in to address the critical issues of income assessment and functional disability in motor accident claims. Justices Sanjay Karol and Prashant Kumar Mishra presided over the case of Jitendra v. Sadiya & Ors., ultimately enhancing the compensation awarded to the appellant.

Case Background

On September 25, 2016, at approximately 8:45 p.m., Jitendra, a 25-year-old, was working with a thresher machine connected to Respondent No. 1’s tractor. Due to the rash and negligent driving of Respondent No. 2, the tractor driver, Jitendra’s hand was caught in the thresher, causing severe injuries to his hand, shoulder, head, and ear. He was rushed to Sanyog Hospital in Indore, where his hand was amputated below the elbow.

An FIR was filed on October 4, 2016, at Police Station Depalpur against Respondent No. 2 under Sections 279 (rash driving), 337 (causing hurt by act endangering life), 338 (causing grievous hurt by act endangering life), and 287 (negligent conduct with respect to machinery) of the Indian Penal Code.

Jitendra, identifying himself as the sole breadwinner of his family, filed a claim for Rs. 20,00,000/- under the Motor Vehicle Act, 1988, citing his inability to perform daily tasks due to the amputation. At the time of the accident, he was earning Rs. 9,000/- per month as a labourer.

Timeline

Course of Proceedings

The Motor Accident Claims Tribunal (MACT) initially awarded Jitendra Rs. 3,76,090/- with 6% interest, based on a 20% permanent disability assessment and a notional income of Rs. 60,000/- per annum.

Dissatisfied with the compensation amount, Jitendra appealed to the High Court, arguing that the Tribunal had incorrectly assessed the permanent disability, future prospects, and treatment expenses.

The High Court enhanced the compensation to Rs. 6,61,690/-, increasing the disability percentage to 40%. The High Court’s calculation included considerations for monthly income, future prospects, permanent disability, loss of income during treatment, medical expenses, pain and suffering, special diet, attendant charges, conveyance, and the cost of an artificial hand.

Legal Framework

The case involves the following legal provisions:

• Sections 279, 337, 338, and 287 of the Indian Penal Code: These sections pertain to rash driving, causing hurt by act endangering life, causing grievous hurt, and negligent conduct with respect to machinery, respectively.
• Motor Vehicle Act, 1988: This act provides the framework for claiming compensation in motor accident cases.

Arguments

The Claimant-Appellant, Jitendra, challenged the High Court’s decision, primarily on the following grounds:

• Extent of Permanent Disability: According to the certificate issued by PW2, Jitendra suffered a 60% permanent disability, leading to a 100% functional disability, rendering him unable to continue his occupation as a labourer.
• Income Assessment: Jitendra’s income should be assessed at more than Rs. 5000/-, as the minimum wage in 2016 was Rs. 6,850/-.

Issues Framed by the Supreme Court

1. What should be the appropriate assessment of the appellant’s income, considering the minimum wage prevalent at the time of the accident?
2. What is the extent of functional disability suffered by the appellant due to the amputation of his hand, and how should it be factored into the compensation?

Treatment of the Issue by the Court

Authorities

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

✓ Gurpreet Kaur and Ors. v. United India Insurance Company Ltd. and Ors.*: The court relied on this authority to consider notifications under the Minimum Wages Act as a guiding factor in cases where there is no evidence available to evaluate monthly income.

✓ National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680: The court relied on this authority to calculate future prospects by adding 40% to the yearly income.

✓ Kajal v. Jagdish Chand (2020) 4 SCC 413: The court relied on this authority for awarding Rs. 10,000/- towards medical expenses.

✓ Sidram v. Divisional Manager, United India Insurance Ltd. (2023) 3 SCC 439: The court relied on this authority for awarding Rs. 40,000/- towards special diet and transportation.

✓ K.S. Muralidhar v. R. Subbulakshmi and Anr. 2024 SCC Online SC 3385: The court relied on this authority for awarding Rs. 2,00,000/- towards pain and suffering.

✓ Raj Kumar v. Ajay Kumar (2011) 1 SCC 343: The court relied on this authority for awarding Rs. 6850/- towards loss of income during treatment.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the need to provide fair and just compensation to the appellant, considering the severe impact of the amputation on his ability to earn a livelihood. The court emphasized the importance of considering the minimum wage prevalent at the time of the accident and the extent of functional disability.

Fact:Law Ratio

The Supreme Court’s decision was influenced by both factual and legal considerations.

Logical Reasoning

✓ Issue 1: What should be the appropriate assessment of the appellant’s income, considering the minimum wage prevalent at the time of the accident?

✓ Issue 2: What is the extent of functional disability suffered by the appellant due to the amputation of his hand, and how should it be factored into the compensation?

The following flowchart demonstrates the logical reasoning of the court:

The Supreme Court enhanced the compensation based on the following reasons:

• The minimum wage prevalent in the area for unskilled workers was Rs. 6,850/-.
• The amputation of the appellant’s right hand significantly hampered his ability to work as a labourer, justifying an increase in the percentage of functional disability to 80%.

Key quotes from the judgment:

✓ “…the notifications under the Minimum Wages Act can be a guiding factor in cases where there is no evidence available to evaluate monthly income.”

✓ “…due to the amputation of his right hand, his ability to work as a labourer would be significantly hampered.”

✓ “…we deem it appropriate to increase the percentage of functional disability to 80%.”

Key Takeaways

• Minimum wages are a crucial factor in determining compensation in motor accident claims, especially when there is a lack of evidence regarding the claimant’s income.
• Functional disability should be assessed realistically, considering the impact of the injury on the claimant’s ability to earn a livelihood.
• The Supreme Court’s decision reinforces the principle of fair and just compensation in motor accident cases, ensuring that victims are adequately compensated for their losses.

Directions

The impugned Award dated 21st June, 2021 passed in Claim Case No.1200314 of 2016 by the 4th Additional Member, Motor Accident Claims Tribunal, Indore as modified in terms of the impugned order, stands further modified to the above extent. Interest is to be paid as awarded by the Tribunal.

Development of Law

The ratio decidendi of the case is that in assessing compensation for motor accident claims, the minimum wage prevalent at the time of the accident should be a guiding factor, and functional disability should be assessed realistically, considering the impact of the injury on the claimant’s ability to earn a livelihood. This decision reinforces the importance of fair compensation in such cases.

Conclusion

In Jitendra v. Sadiya & Ors., the Supreme Court enhanced the compensation awarded to a labourer who lost his hand in a thresher machine accident. The Court emphasized the importance of considering the minimum wage and realistically assessing functional disability, ensuring fair and just compensation for the victim.