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M. Seetharama @ Seetharama Gowda vs The Manager Future General India Insurance Co. Ltd.

Supreme Court8 May 2025Sudhanshu Dhulia

Ratio decidendi

The rule this decision rests on

When assessing compensation for loss of future income in motor accident claims involving permanent disability, the court must: (1) determine the injured person's actual income by reference to contemporary wage standards for the relevant class of worker, applying incremental increases as established in precedent; (2) apply the assessed percentage of disability to that income; and (3) additionally apply a percentage for loss of future prospects (in this case 40%) to account for the claimant's reduced earning capacity over the remainder of the working life, calculated over the appropriate period and multiplied by 12 for monthly computation. Medical expenses actually proved by documentary evidence must be awarded in full, with an additional composite amount for ancillary claims such as special diet, conveyance and attendant charges that are not separately substantiated by bills. Compensation for pain and suffering in cases of severe permanent disability such as amputation must reflect the overall suffering endured, including the nature and extent of injuries and their functional impact, and is not limited by the amounts awarded by lower courts where those amounts do not adequately compensate for the gravity of the injury.

Written by Miss Lucy from the judgment below, not taken from a headnote.

Judgment

As delivered

2025 INSC 648

Non-Reportable

IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION

Civil Appeal No…………..of 2025 (@Special Leave Petition (C) No.14543 of 2023)

M. SEETHARAMA @ SEETHARAMA GOWDA

.…APPELLANT VERSUS

THE MANAGER FUTURE GENERAL INDIA INSURANCE CO. LTD. & ORS. .…RESPONDENTS

J U D G M E NT

K. VINOD CHANDRAN, J.

1. Leave granted.

2. The appellant was injured in an accident which

occurred on 25.06.2015 when the bike he was riding

collided with a jeep. The FIR was registered against the

jeep driver who was driving on the right side at high

speed as also rashly and negligently. The appellant

having suffered multiple injuries was taken to a local Signature Not Verified Digitally signed by Jayant Kumar Arora Date: 2025.05.08 16:11:30 IST Reason: Page 1 of 6 CA @SLP(C) No. 14543 of 2023 hospital where he was discharged after first aid and

then admitted to a specialist hospital where he spent

one and a half months. The appellant produced medical

bills and also asserted an income of Rs.12,000/- per

month. The appellant was aged 38 years and he suffered

Syme’s amputation. The Tribunal awarded a total amount

of Rs. 6,60,000/- under various heads which was

increased by the High Court to Rs.12,65,000/-.

3. Compensation under different heads as awarded

by the High Court: -

Sr. No. Heads of Claim Amount 1. Loss of income. Rs.8,10,000/- Rs.9000 x 12 x 15 x 50% 2. Medical expenses. Rs.1,90,000/-

3. Loss of income during laid Rs. 45,000/-

up period.

4. Loss of amenities. Rs. 75,000/-

5. Future medical expenses. Rs.25,000/-

6. Pain and suffering. Rs.1,20,000/-

Total amount Rs.12,65,000/-

Page 2 of 6 CA @SLP(C) No. 14543 of 2023

4. The High Court had confirmed the order of the

Tribunal which awarded an amount of Rs. 1,20,000/- for

pain and suffering. As is evident from the order of the

Tribunal, the appellant suffered multiple injuries and

had a fracture in the right femur, right clavicle, right

tibia and fibula with vascular compromise. Considering

the over-all suffering as also the amputation which was

at the ankle joint, preserving the heel pad to allow for

weight bearing; which is what a Syme’s amputation is,

the compensation for pain and suffering can be

increased to Rs. 1,50,000/-.

5. As far as medical expenses, despite producing

bills for Rs. 1,86,486/-, the Tribunal and the High Court

only awarded an amount of Rs. 1,90,000/; including for

special diet, conveyance and attendant charges. This

Court is of the opinion that the medical bills proved has

to be granted in full and for special diet, conveyance

Page 3 of 6 CA @SLP(C) No. 14543 of 2023 and attendant charges a composite amount of Rs.

30,000/- can be awarded.

6. For loss of future income, the Tribunal adopted an

income of Rs. 7,000/- which was enhanced to Rs. 9,000/-

by the High Court. Ramachandrappa v. Royal

Sundaram Alliance Insurance Co. Ltd.1, (supra) was a

case in which even a coolie’s income was determined at

Rs. 4,500/- in the year 2004. As has been held in Pranay

Sethi2, there can be an incremental increase for every

year which at the least will be at Rs.500/- for every

successive year. Taking that into account, the salary of

an unskilled worker will be Rs.10,000/- in the year 2015

when the accident occurred. The claimant had

produced income certificate and PW3 was examined to

prove the same. The Tribunal, however, disbelieved

PW3. But, in any event, the income of the injured can be

fixed at Rs. 10,000/-. When assessing his loss of income

1 (2011) 13 SCC 236 2 (2017) 16 SCC 680

Page 4 of 6 CA @SLP(C) No. 14543 of 2023 for 50% disability, as held by the High Court,

necessarily, 40% for future prospects has to be added.

We find no reason to increase the percentage of

disability as assessed by the Doctor. The amounts

granted will be as under:-

Sr. No. Heads of Claim Amount 1. Pain and suffering Rs.1,50,000/- 2. Medical expenses. Rs.1,86,486/-

3. Special diet, conveyance and Rs.30,000/-

attendant charges.

4. Loss of amenities. Rs.10,000/-

5. Loss of future income. Rs. 12,60,000/-

Rs. 10,000/- x 140% x 12 x 15 x 50%

6. Future medical expenses. Rs. 25,000/-

7. Loss of income during Rs. 45,000/-

hospitalization.

Total amount Rs.17,06,486/-

7. The awarded amounts shall be paid within a

period of two months from today with interest @ 9% per

annum and whatever amounts have already been paid

Page 5 of 6 CA @SLP(C) No. 14543 of 2023 shall be deducted. The appellant shall provide the bank

account details to the Insurance Company who shall

transfer the amount online within the period specified

hereinabove.

8. The Appeal stands allowed with the above

directions.

9. Pending application(s), if any, shall stand disposed

of.

…………..……………, J.

[SUDHANSHU DHULIA]

……………..……………, J.

[K. VINOD CHANDRAN] NEW DELHI;

MAY 08, 2025.

Page 6 of 6 CA @SLP(C) No. 14543 of 2023

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