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Supreme Court of India 2020-09-17 partly_allowed

PAPPU DEO YADAV vs NARESH KUMAR AND ORS

Bench: 3 — L. Nageswara Rao, Krishna Murari, S. Ravindra Bhat

In Brief

On 18 May 2012, a 20-year-old data entry operator and bus passenger was seriously injured when another bus negligently collided with his bus, resulting in amputation of his right arm with 89% assessed disability. He sought ₹50 lakhs compensation. The Motor Accident Claims Tribunal awarded ₹14.25 lakh, but the High Court reduced the disability assessment to 45% and the loss-of-earning head to ₹7.77 lakh, denying future prospects. The Supreme Court held that: (1) future prospects compensation (40% addition) is available even in permanent disability cases, not just death; (2) disability assessment must reflect actual functional impact on earning capacity relative to the victim's specific profession, not mechanical scaling; (3) the victim's income of ₹12,000 per month should be realistically assessed at ₹10,000 monthly, with future prospects yielding ₹14,000; and (4) compensation for serious injury must be "just" and reflect the profound physical, mental, and emotional trauma. The Court substituted ₹19.65 lakh for loss of earning capacity, partly allowing the appeal.

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Motor Vehicle Accident Compensation Personal Injury Permanent Disability Loss of Earning Capacity Future Prospects

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