Employment Sustained by “Corporate Compassion” Does Not Negate 100% Functional Disability: Supreme Court Enhances MACT Compensation to ₹3.77 Crore
Case Name: Reliance General Insurance Company Limited v. Priyanka Das and Others
Date of Judgment: 3 September 2026
Citation: 2026 INSC 950
Bench: Justice S.V.N. Bhatti and Justice N.V. Anjaria
Held: The Supreme Court held that functional disability in motor accident compensation cases must be assessed with reference to the injured claimant’s capacity to independently obtain, retain and progress in employment in the open competitive market. Continued employment in a specially accommodated position does not necessarily establish the absence of loss of earning capacity. Where an employee can continue working only because of assistive software, flexible working arrangements and exceptional support extended by a compassionate employer, such employment cannot be treated as proof that the claimant retains an equivalent earning capacity in the general labour market.
On the peculiar facts, the Court treated the claimant’s 100 per cent permanent physical impairment as 100 per cent functional disability because complete blindness, a permanent colostomy and serious pelvic injuries had extinguished her independent ability to secure, sustain or advance in employment. The Court expressly clarified that its grant of ₹20 lakh for loss of marriage prospects was based on the exceptional circumstances of the case and should not be treated as a precedent.
The Court also reaffirmed that the multiplier in a fatal motor accident claim must be selected with reference to the age of the deceased and not the age of the dependants. For a deceased person aged thirty-three years, the appropriate multiplier under Sarla Verma v. Delhi Transport Corporation, as approved in National Insurance Co. Ltd. v. Pranay Sethi, is sixteen. Negligence in proceedings before a Motor Accident Claims Tribunal is determined on the preponderance of probabilities and not according to the criminal standard of proof beyond reasonable doubt.
Summary: On 10 April 2011, Sushant Prabhakaran and Priyanka Das were travelling on a motorcycle near Brijghat Bridge when a heavy goods vehicle bearing registration No. HR-55-2812 struck them. The truck ran over Sushant, causing his instantaneous death, while Priyanka suffered catastrophic injuries. An FIR was registered at Police Station Gadmukteshwar on the complaint of an independent passerby. The truck was insured by Reliance General Insurance Company Limited.
At the time of his death, Sushant was thirty-three years old and employed as Manager, Contact Centre, with Ericsson India Private Limited. Priyanka claimed compensation by asserting that she was his legally wedded wife, while his parents were also impleaded in the claim proceedings. The Motor Accident Claims Tribunal awarded ₹82,56,152 for Sushant’s death but found that Priyanka had failed to prove a lawful marriage. Employment records described Sushant as her fiancé, and she was found to be financially independent. The Tribunal therefore apportioned ₹5 lakh to Priyanka, ₹50,000 to the deceased’s father and ₹77,06,152 to his mother.
The Punjab and Haryana High Court increased Priyanka’s share to ₹7.5 lakh but otherwise maintained the material findings. Reliance General Insurance challenged the quantum of compensation, while Priyanka challenged the refusal to recognise her as the deceased’s legally wedded wife and the resulting apportionment.
The Supreme Court found no basis to disturb the concurrent finding that Priyanka had not proved her status as Sushant’s legally wedded wife. The burden to establish the marriage rested upon her even though MACT proceedings are summary in nature. The Court also declined to interfere with the compensation apportioned to her under the principle recognised in Manjuri Bera v. Oriental Insurance Co. Ltd., observing that compensation must remain just and fair so that what is legitimately due is not denied and what is undeserving is not granted.
The insurer’s argument that the multiplier should correspond to the age of the deceased’s parents was rejected. The Court reiterated that the position is conclusively settled by Sarla Verma, Pranay Sethi, Munna Lal Jain v. Vipin Kumar Sharma and Sube Singh v. Shyam Singh: the multiplier is determined by the age of the deceased, including where the deceased was a bachelor and the claimants are the parents. Since Sushant was thirty-three years old, the Tribunal and High Court correctly applied a multiplier of sixteen.
The second set of appeals concerned compensation for Priyanka’s own injuries. Following the accident, she underwent extensive treatment at several hospitals for pelvic fractures, severe injuries to the perineal region and third-degree friction burns. Despite multiple surgical procedures, the continuity of her large intestine could not be restored. She was left dependent upon a permanent colostomy stoma for life. She also suffered traumatic bilateral occipital gliosis resulting in complete and incurable blindness.
Priyanka was thirty-five years old at the time of the accident and was employed as Deputy Group Manager with IBM Daksh, later Concentrix Daksh Services India Private Limited. She claimed ₹12 crore as compensation for her injuries, loss of earning capacity, medical expenditure, need for lifelong assistance and diminished quality of life.
The Tribunal initially assessed her functional disability at sixty per cent. Although the medical evidence showed complete visual disability and serious permanent physical consequences, the Tribunal noted that she remained employed and that her cost-to-company had increased after the accident. It awarded total compensation of ₹1,35,53,298.
The High Court increased her functional disability to eighty per cent. It found that Priyanka could perform her duties only through specialised assistive software provided by her employer. An official career-growth letter also demonstrated that she had lost normal promotional opportunities and advancement to senior positions such as General Manager, Director or Vice President because of the accident. The High Court awarded fifty per cent towards future prospects and enhanced the total compensation to ₹2,94,82,617.
During the proceedings before the Supreme Court, Priyanka was examined by a multidisciplinary Medical Board at Vardhman Mahavir Medical College and Safdarjung Hospital, New Delhi. The Board comprised specialists from neurology, neurosurgery, ophthalmology, general surgery and physical medicine and rehabilitation. Its report certified that Priyanka had suffered 100 per cent permanent physical impairment of the whole body.
The insurer argued that even if the physical impairment was assessed at 100 per cent, Priyanka’s functional disability should remain lower because she continued to hold employment and had received salary increments. The Supreme Court rejected this contention. It observed that the insurer had accepted the proposal for an independent medical re-examination and could not disregard the report merely because its findings did not support the insurer’s position.
More importantly, the Court held that continued employment must be examined in its proper context. Priyanka remained capable of performing limited professional functions only because her employer provided specially developed software, flexible working hours and extensive workplace accommodations. The Court characterised this support as an act of “corporate compassion.” Such exceptional assistance from a particular employer could not be equated with an unimpaired capacity to compete for employment in the open market.
The Court found that Priyanka’s complete blindness, permanent colostomy, pelvic injuries and lifelong dependence upon assistance had extinguished her ability to independently obtain, retain and progress in employment outside her highly accommodated role. It accordingly increased her functional disability from eighty to 100 per cent.
Her monthly income was assessed at ₹84,057 and her annual income at ₹10,08,684. After adding fifty per cent for future prospects and applying a multiplier of sixteen, the Court calculated the loss of future earning capacity at ₹2,42,08,416. It also awarded ₹35,48,798 towards medical bills, ₹28.80 lakh for three attendants required for round-the-clock care, ₹15,97,083 for income lost during nineteen months of treatment, ₹15 lakh towards future medical expenses and ₹15 lakh for pain, suffering and mental agony.
Priyanka was additionally awarded ₹20 lakh for loss of marriage prospects, ₹2 lakh for special diet, ₹2 lakh for loss of amenities and disfigurement, and ₹1.5 lakh for transportation. The Court stressed that the compensation was determined in the exceptional circumstances of the case to provide just and fair redress for the devastating and lifelong impact of the accident.
Decision: The Supreme Court dismissed Civil Appeal,concerning compensation arising from Sushant Prabhakaran’s death. It upheld the application of multiplier sixteen, the finding that Priyanka had not proved her status as the deceased’s legally wedded wife, and the apportionment granting her ₹7.5 lakh from the compensation awarded for his death.