2026 INSC 950
Civil Appeal Nos. 12085–12086 of 2026 with Civil Appeal Nos. 12087–12089 of 2026
Supreme Court of India — Civil Appellate Jurisdiction
Coram: S.V.N. Bhatti, J. and N.V. Anjaria, J. | Decided on: 03.09.2026
BACKGROUND
Two connected sets of Motor Accident Claims Tribunal (“MACT”) appeals arose from a single road accident on
10.04.2011 near Brijghat Bridge, when a heavy goods vehicle (Registration No.
HR-55-2812) struck a motorcycle carrying
Sushant Prabhakaran (driver) and
Priyanka Das (pillion rider). Prabhakaran died instantaneously; Das suffered grievous, life-altering injuries. FIR No. 198/2011 was registered at PS Gadmukteshwar on the complaint of a passerby, Radhe Shyam Kaushik.
Two separate MACT petitions followed, each culminating in cross-appeals before the Punjab and Haryana High Court and, thereafter, before the Supreme Court:
- Death Claim — MACT Petition No. 9 of 2014, filed by Priyanka Das claiming Rs. 5 crore, with the deceased’s parents arrayed as proforma respondents.
- Injury Claim — MACT Petition No. 94 of 2014, filed by Das for her own injuries, claiming Rs. 12 crore.
THE DEATH CLAIM
Civil Appeal Nos. 12085–12086 of 2026
The
Tribunal (Award dated 03.04.2017) determined total compensation of
Rs. 82,56,152/-, apportioned as Rs. 5,00,000/- to Priyanka Das, Rs. 50,000/- to the father, and Rs. 77,06,152/- to the mother. Critically, the Tribunal declined to treat Das as the deceased’s legally wedded wife for want of documentary proof of marriage, instead recognising her — on the strength of employment records — as his fiancée.
The
High Court (Order dated 24.01.2019) made only a marginal enhancement, raising Das’s share from Rs. 5,00,000/- to Rs. 7,50,000/-, while otherwise affirming the award.
Supreme Court’s Findings
- Negligence: Concurrent findings that the accident was caused by the truck driver’s rash and negligent driving were upheld, resting on Das’s eyewitness testimony (PW-9), the physical evidence of the crushed motorcycle, and admissions made by the truck driver in cross-examination.
- Multiplier: For a deceased bachelor, the applicable multiplier is anchored to the deceased’s age — never the dependents’ — as settled in Sarla Verma v. Delhi Transport Corporation (2009), Munna Lal Jain v. Vipin Kumar Sharma (2015), and Sube Singh v. Shyam Singh (2018). At age 33 (bracket 31–35), a multiplier of 16 was correctly applied per the Sarla Verma/Pranay Sethi
- Marital Status: The Court declined to re-appreciate concurrent findings that Das had failed to discharge her burden of proving she was the legally wedded wife.
- Apportionment: The plea for a higher share to Das beyond the near-token apportionment was rejected, relying on Manjuri Bera v. Oriental Insurance Co. Ltd. (2007) — mathematical precision is not the touchstone in such matters; just and fair compensation is.
Result: Both appeals dismissed; the High Court’s judgment stands affirmed.
THE INJURY CLAIM
Civil Appeal Nos. 12087–12089 of 2026
The
Tribunal (Award dated 03.04.2017) assessed functional disability at
60% and awarded
Rs. 1,35,53,298/-, notwithstanding a certified 100% physical/visual disability, reasoning that Das continued in employment (at an increased Cost to Company) through specially created assistive software.
The
High Court enhanced functional disability to
80% and future prospects to
50%, raising the total to
Rs. 2,94,82,617/-, relying on
Pappu Deo Yadav v. Naresh Kumar (2022) for the principle that disability assessment must track the loss of income-generating capacity in the open market rather than mere retention in an accommodated role.
The Court-Directed Medical Board
By order dated 17.10.2025, the Supreme Court directed a fresh, multi-disciplinary medical evaluation at
Vardhman Mahavir Medical College & Safdarjung Hospital, New Delhi. The Board’s report dated 28.02.2026 certified
100% Permanent Physical Impairment of the whole body, corroborating pre-existing AIIMS findings of total bilateral cortical blindness and a permanent colostomy.
Key Legal Reasoning
- The Insurer’s argument — that continued employment negated functional disability — was rejected. Having itself sought the fresh Medical Board evaluation, the Insurer could not resile from an unfavourable outcome.
- Functional disability must be measured against earning capacity in the open, competitive labour market, not survival in a specially accommodated role. A Career Growth Letter confirming stalled promotions (only 4 in 15 years, with advancement to GM/Director/VP level foreclosed) was treated as direct evidence of lost earning capacity.
- Functional disability was accordingly raised from 80% to 100%.
Revised Compensation
| Head of Compensation |
Amount (Rs.) |
| Loss of Future Earning Capacity (100% disability, 50% future prospects, multiplier 16) |
2,42,08,416 |
| Medical Bills Reimbursement |
35,48,798 |
| Attendant Charges (3 attendants, 24Ă—7 care) |
28,80,000 |
| Loss of Income During Treatment (19 months) |
15,97,083 |
| Future Medical Expenses |
15,00,000 |
| Pain, Suffering & Mental Agony |
15,00,000 |
| Loss of Marriage Prospects |
20,00,000 |
| Special Diet |
2,00,000 |
| Loss of Amenities of Life & Disfiguration |
2,00,000 |
| Transportation Charges |
1,50,000 |
| TOTAL COMPENSATION |
3,77,84,297 |
Interest was awarded at
7.5% per annum from the date of the claim petition until realisation.
Result: The Insurer’s appeals (Civil Appeal Nos. 12087–12088 of 2026) were dismissed; the Claimant’s appeal (Civil Appeal No. 12089 of 2026) was allowed in part, enhancing compensation to
Rs. 3,77,84,297/-.
KEY TAKEAWAYS FOR PRACTICE
- Multiplier for a bachelor deceased: Settled law — always the deceased’s age, never the dependents’, irrespective of who ultimately receives the award.
- Functional vs. actual disability: Continued employment or salary increments post-accident do not defeat a high functional-disability claim where the claimant works only through extraordinary accommodation; the touchstone is open-market employability.
- Court-directed medical evaluation: Courts retain discretion to direct fresh medical board evaluations even at the Supreme Court stage. A party that invites such an evaluation cannot later dispute an adverse finding.
- Apportionment disputes: Absence of documentary proof of marriage is fatal to a claimed spouse’s status as primary dependent, even where cohabitation or employment records suggest a relationship.
Technologies